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Edited version of private advice
Authorisation Number: 1051605781010
Date of advice: 14 November 2019
Ruling
Subject: Controlled Foreign Company (CFC) rules
In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided.
The taxpayer sought a ruling on the application of CFC rules and in particular, whether they have an attribution percentage greater than nil in relation to an indirectly held subsidiary.
The Commissioner ruled that the taxpayer is an 'attributable taxpayer' with an attribution percentage greater than nil in relation to their indirectly held subsidiary.
Relevant legislative provisions
Income Tax Assessment Act 1936 section 362