Apart from the FIF regime, there are two other components of the foreign source income attribution regime:
- the CFC measures, and
- the transferor trust measures.
These measures attribute specified income and gains of foreign companies and trusts to certain Australian residents - known as attributable taxpayers.
If the FIF measures overlap with the other components of the foreign source income regime, the CFC or transferor trust measures apply and, in general, the FIF measures will not apply. However, if a CFC, either directly or through a CFT or transferor trust, holds an interest in a FIF, the FIF measures do apply in working out the attributable income of those entities. [sections 492, 493 and 494]