Income Tax Assessment Act 1936

PART X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES  

Division 9 - Attribution of attributable income and other amounts  

SECTION 460A   EFFECT OF REDUCING SECTION CGT EVENT J1 AMOUNT  

460A(1)   [Application]  

This section applies in either of the following cases:

(a) one or more schemes or arrangements have the effect of reducing the attribution percentage of an attributable taxpayer in relation to a company that is a CFC, and are intended by the attributable taxpayer or an associate of the attributable taxpayer to have that effect;

(b) a company ceases to be a CFC in relation to a particular taxpayer.

460A(2)   [Calculating amount]  

Work out the amount (if any) included under this Division in the taxpayer's assessable income because of CGT event J1 (as it notionally happens to the company under Division 7 ) as though the reduction or cessation had not happened.

Note:

CGT event J1 is about companies ceasing to be related after a roll-over.