Complete by placing an 'X' in the applicable box.
This information will help us to identify if there is a risk that a transaction has occurred to which section 47A of the ITAA 1936 would apply.
When a CFC resident in an unlisted country provides, either directly or indirectly, an eligible benefit to an associated entity, section 47A can apply to deem that benefit a dividend.
Unless otherwise specified, the terms in this question have the same meaning as set out in section 47A of the ITAA 1936.
Broadly, a benefit is defined in section 47A to include the following:
- a waiver or release of an obligation to pay or repay an amount (waiver of debts)
- the granting of a non-arm's length loan
- transfers of property or services for no or inadequate consideration
- the payment of a call on an allotment of shares
- share or unit acquisitions for non-arms length consideration.
For more detailed information, refer to:
- section 47A of the ITAA 1936
- Taxation Ruling TR 2002/2 Income tax: meaning of "Arm's Length" for the purpose of subsection 47A(7) of the Income Tax Assessment Act 1936 (ITAA 1936) dividend deeming provisions.