22 Attributed foreign income
If the partnership was a subsidiary member of a consolidated group or MEC group for the entire income year, the International dealings schedule 2015 is not required.
Where the partnership is a member of a consolidated group or MEC group for the whole income year and derived foreign income, the responsibility for preparing the schedule will rest on the head company of the group.
Where a return is required because the partnership had a period in the income year when it was not a member of a consolidated group or MEC group (a non-membership period), the partnership should complete an International dealings schedule where it has derived foreign income attributable to any non-membership period.
See also:
Did you have overseas branch operations or a direct or indirect interest in a foreign trust, foreign company, controlled foreign entity or transferor trust?
Direct or indirect interests in a controlled foreign company or a foreign trust are taken to have the same meaning as set out in Division 3 of Part X of the ITAA 1936.
A partnership has an interest in a transferor trust if the partnership has ever made, or caused to be made, a transfer of property or services to a non-resident trust. Transfer of property and services is defined in section 102AAB of the ITAA 1936.
Sections 102AAJand 102AAK of the ITAA 1936 provide guidance on whether there was a transfer, or a deemed transfer, of property or services to a non-resident trust.
Yes Print X in the Yes box at S and complete an International dealings schedule 2015.
No Print X in the No box at S.
See also:
Listed country
Show at M the amount of gross attributed foreign income from controlled foreign entities and transferor trusts of listed countries. Listed countries are set out in Part 1 of Schedule 10 to the Income Tax Regulations 1936 (ITR 1936).
Attributed foreign income is the income attributed to the taxpayer from controlled foreign entities, calculated in accordance with Division 7 of Part X of the ITAA 1936, and includes an amount grossed-up under section 392 of the ITAA 1936, to the extent of any foreign taxes paid.
Show at M the amount of income attributed from a transferor trust that is a listed country trust estate, calculated in accordance with Subdivision D of Division 6AAA of the ITAA 1936.
A listed country trust estate is defined in section 102AAE of the ITAA 1936.
Section 404 country
Show at U the amount of attributed foreign income from controlled foreign entities in section 404 countries. Section 404 countries are listed in Part 2 of Schedule 10 to the ITR 1936.
Also show at U the amount of income attributed from a transferor trust if the entire income and profits of the trust are subject to tax in a section 404 country. Do not include the amount if it is shown at M.
Unlisted country
Show at X the amount of attributed foreign income from controlled foreign entities in unlisted countries. Unlisted countries are countries that are not listed in Schedule 10 to the ITR 1936.
Show at X the amount of income attributed from a transferor trust if the amount has not been shown at M or U.