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Legislation
ATO documents that consider ITAA 1936 s 456
5 documents
Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities
Compendium
Controlled Foreign Companies: attribution of foreign income to Australian entity with de facto control of foreign entity - no direct or indirect attribution interest in that entity
Income tax: Foreign Income: is a lump sum payment received by a CFC (Controlled Foreign Company) as consideration for the assignment of an interest stream attributable under section 456 of the Income Tax Assessment Act 1936?
Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities