Consolidation Reference Manual

The Consolidation reference manual was last updated on 15 July 2011. It does not contain any changes to consolidation legislation that has occurred since that time and will not be updated in future. It cannot be relied on for currency of content. For any future consolidation changes, you will be able to access information from our consolidation home page or by visiting our 'New legislation' page.
You can still refer to the Consolidation reference manual for consolidation information that has not been impacted by changes in the legislation.

C6 International

C6-0 About this section

About this section
Section C6 provides technical detail on the consolidation rules for: • the treatment of foreign income tax offsets • transferring and using excess foreign tax credits • transferring attribution surpluses relating to controlled foreign companies, foreign investment funds and foreign life assurance policies • the treatment of conduit foreign income • transferring foreign dividend account balances, and • inheriting irrevocable elections or choices in relation to interests in CFCs, FIFs or FLPs. This section has an overall explanation of these rules and detailed worked examples showing the processes and calculations involved. For a brief description of the above rules see Part B ('Treatment of foreign income tax offsets, excess foreign tax credits, attribution surpluses, conduit foreign income and irrevocable elections', B2-5).

About this section

Section C6 provides technical detail on the consolidation rules for:

•: the treatment of foreign income tax offsets
•: transferring and using excess foreign tax credits
•: transferring attribution surpluses relating to controlled foreign companies, foreign investment funds and foreign life assurance policies
•: the treatment of conduit foreign income
•: transferring foreign dividend account balances, and
•: inheriting irrevocable elections or choices in relation to interests in CFCs, FIFs or FLPs.

This section has an overall explanation of these rules and detailed worked examples showing the processes and calculations involved.

For a brief description of the above rules see Part B ('Treatment of foreign income tax offsets, excess foreign tax credits, attribution surpluses, conduit foreign income and irrevocable elections', B2-5).

Current at 30 June 2009

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