Private ruling: Controlled Foreign Company (CFC) rules
Date of advice: 14 November 2019
Published: February 2020

Ruling: 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