Document ID: chunk:federal_register_of_legislation:C2025C00014:section:204:p3
Version: federal_register_of_legislation:C2025C00014
Segment Type: section
Provision Reference: s 204 (pt 3/6)
Character Range: 1749072–1752103

Part X—Attribution of income in respect of controlled foreign companies
Division 1—Preliminary
316 Object of Part
317 Interpretation
318 Associates
319 Statutory accounting period of a company
320 Listed countries and unlisted countries
321 Each listed country and each unlisted country to be treated as a separate foreign country
322 Meaning of entitled to acquire
323 State foreign taxes may be treated as federal foreign taxes
324 When income or profits subject to tax in a listed country
325 When dividends etc. taxed in a country at normal company tax rate
326 AFI subsidiary
327 Eligible finance shares
327A Widely distributed finance shares
327B Transitional finance shares
328 Non‑resident family trusts
329 Public unit trusts
330 Tax detriment
331 Company deemed to be treated as a resident of a listed country or an unlisted country for the purposes of the tax law of that country
332 Companies that are residents of listed countries
333 Companies that are residents of unlisted countries
334A Voting interests in companies
335 References extend to pre‑commencement matters and things
Division 2—Types of entity
Subdivision A—Australian entities
336 Australian entity
337 Australian partnership
338 Australian trust
Subdivision B—Controlled foreign entities (CFEs)
339 Controlled foreign entity (CFE)
340 Controlled foreign company (CFC)
341 Controlled foreign partnership (CFP)
342 Controlled foreign trust (CFT)
Subdivision C—Eligible transferors in relation to trusts
343 Interpretation
344 References to transfer of property or services
345 Deemed transfers of property or services
346 Circumstances in which a transfer of property or services is an eligible business transaction
347 Eligible transferor in relation to a discretionary trust
348 Eligible transferor in relation to a non‑discretionary trust or a public unit trust
Division 3—Control interests, attribution interests, attributable taxpayers and attribution percentages
Subdivision A—Control interests
349 Associate‑inclusive control interest in a company or trust
350 Direct control interest in a company
351 Direct control interest in a trust
352 Indirect control interest in a company or trust
353 Control tracing interest in a company
354 Control tracing interest in a CFP
355 Control tracing interest in a CFT
Subdivision B—Attribution interests
356 Direct attribution interest in a CFC or CFT
357 Indirect attribution interest in a CFC or CFT
358 Attribution tracing interest in a CFC
359 Attribution tracing interest in a CFP
360 Attribution tracing interest in a CFT
Subdivision C—Attributable taxpayers and attribution percentages
361 Attributable taxpayer in relation to a CFC or a CFT
362 Attribution percentage of an attributable taxpayer
Division 4—Attribution accounts
363 Attribution account entity
364 Attribution account percentage
365 Attribution account payment
366 Direct attribution account interest in a company
367 Direct attribution account interest in a partnership
368 Direct attribution account interest in a trust
369 Indirect