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Key changes for attribution corporate collective investment vehicle sub-funds

Key changes and new measures affecting your clients in 2023 attribution CCIV sub-fund tax returns.

Last updated 19 July 2023

Corporate collective investment vehicles

The Corporate Collective Investment Vehicle Framework and Other Measures Act 2022 establishes the regulatory and tax frameworks for corporate collective investment vehicles (CCIVs).

The CCIV tax framework leverages the existing trust taxation framework and the existing attribution flow-through regime (that is, the Attribution managed investment trust (AMIT) regime), rather than by creating a new bespoke tax regime.

A CCIV sub-fund trust that satisfies the applicable AMIT eligibility requirements in Division 276 of the ITAA 1997 for an income year will be treated as an AMIT for that year. Such a CCIV sub-fund trust must lodge an Attribution CCIV sub-fund tax return for that income year.

If a CCIV sub-fund trust fails to meet the modified AMIT eligibility criteria in Division 276 of the ITAA 1997, it will be taxed in accordance with the general trust provisions including where the trust is taxed as a public trading trust under Division 6C of Part III of the Income Tax Assessment Act 1936 (ITAA 1936). This type of CCIV sub-fund trust must lodge a Trust tax return for that income year, or if Division 6C applies to the trust, a Company tax return.

If your client meets the AMIT eligibility requirements as an attribution corporate collective investment vehicle (CCIV) sub-fund for the income year, only use Attribution CCIV sub-fund trust tax return instructions and complete the Attribution CCIV sub-fund tax return 2023.

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