If you have an interest in a CFC you must determine if you are an attributable taxpayer. You are only required to include an amount of attributable income from a CFC in your assessable income if you are an attributable taxpayer in relation to the CFC.
You will be an attributable taxpayer if:
- you have an associate-inclusive control interest of 10% or more in a CFC, or
- all of the following rules apply:
- the CFC is a CFC because of the application of the de facto control test
- you are an Australian 1 per cent entity
- you are part of a group of five or fewer Australian entities who, alone or with associates - regardless of whether the associates are Australian entities - control the CFC.