Income Tax Assessment (1997 Act) Regulations 2021
For the purposes of subsection 960-80(7) of the Act, this section provides requirements that an entity must comply with in translating an amount from the applicable functional currency into Australian currency.
Amount that is not the attributable income of a CFC
960-80.03(2)
If, on or after 27 April 2005, an entity translates an amount that is not the attributable income of a CFC from the applicable functional currency into Australian currency on a day in accordance with an item of the table in subsection 960-80(1) of the Act, the entity must translate the amount using: (a) an exchange rate that is an average of all of the exchange rates during the period, not exceeding 12 months, in which the entity carries on the relevant business or other activity; or (b) if the entity makes an election in writing to use the exchange rate applicable on the last day of the entity ' s income year - that exchange rate.
Amount that is the attributable income of a CFC
960-80.03(3)
If, on or after 27 April 2005, an entity that is an attributable taxpayer in relation to a CFC translates an amount that is the attributable income of a CFC from the applicable functional currency into Australian currency on a day in accordance with an item of the table in subsection 960-80(1) of the Act, the entity must translate the amount using: (a) an exchange rate that is an average of all of the exchange rates during the period, not exceeding 12 months, in which the CFC carries on the relevant business or other activity; or (b) if the entity makes an election in writing to use the exchange rate applicable on the last day of the CFC ' s statutory accounting period - that exchange rate.
960-80.03(4)
An election under paragraph (2)(b) or (3)(b) is irrevocable.
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