Document ID: chunk:federal_register_of_legislation:C2025C00014:section:102aat:p3
Version: federal_register_of_legislation:C2025C00014
Segment Type: section
Provision Reference: s 102AAT (pt 3/4)
Character Range: 759092–761796

an entity (in this subsection called the transferor) being a partnership is an attributable taxpayer in relation to the entity's current year of income and in relation to a particular trust estate (in this subsection called the transferee trust estate) because of one or more transfers (being actual transfers or transfers taken to have been made because of subsection 102AAK(1), (2) or (5)) of property or services made by the transferor to the transferee trust estate; or
 (b) an entity (in this subsection also called the transferor) being a trust estate is an attributable taxpayer in relation to the entity's current year of income and in relation to another trust estate (in this subsection also called the transferee trust estate) because of one or more transfers (being actual transfers or transfers taken to have been made because of subsection 102AAK(1), (2) or (5)) of property or services made by the transferor to the transferee trust estate;
the question whether any other entity is an attributable taxpayer in relation to the same year of income and in relation to the transferee trust estate is to be determined as if:
 (c) if paragraph (a) applies—subsection 102AAK(6) did not apply in relation to any of the transfers mentioned in that paragraph; or
 (d) if paragraph (b) applies—subsection 102AAK(8) did not apply in relation to any of the transfers mentioned in that paragraph.
 (3) If:
 (a) apart from this subsection, an entity, being a natural person (other than a natural person in the capacity of a trustee), is not an attributable taxpayer in relation to the entity's current year of income and in relation to a trust estate; and
 (b) apart from paragraph (1)(b), the entity would have been such an attributable taxpayer; and
 (c) apart from subparagraph 102AAH(2)(b)(i) or (3)(a)(ii), the trust estate was not a non‑resident family trust in relation to the natural person at some time after the entity's current year of income when the natural person was alive and the trust estate was in existence;
the following provisions have effect:
 (d) subsection (1) has effect as if paragraph (1)(b) had applied;
 (e) section 170 does not prevent the amendment of an assessment at any time for the purposes of giving effect to this subsection.
 (4) If:
 (a) apart from this subsection, an entity is not an attributable taxpayer in relation to the entity's current year of income and in relation to a trust estate; and
 (b) apart from sub‑subparagraph (1)(a)(i)(E) or (F) or paragraph (1)(c), the entity would have been such an attributable taxpayer; and
 (c) the entity was in a position to control the trust estate at some time after the entity's current year of income when the trust