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Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017

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2016-2017

 

The Parliament of the

Commonwealth of Australia

 

HOUSE OF REPRESENTATIVES

 

 

 

Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017

 

 

(1)     Schedule 1, item 13, page 8 (lines 5 to 12), omit subsection 177J(6), substitute:

Modification where foreign entity is CFC

             (6)  Subsection (6A) applies if:

                     (a)  the foreign entity mentioned in paragraph (1)(d) is a CFC (within the meaning of Part X); and

                     (b)  an amount of attributable income (within the meaning of that Part) of the foreign entity has been included as a result of the operation of that Part in the assessable income of:

                              (i)  the relevant taxpayer; or

                             (ii)  an associate (within the meaning given by section 318) of the relevant taxpayer, if the associate is a Part X Australian resident (within the meaning of that Part) and is not a trust or partnership.

          (6A)  For the purposes of the DPT provisions, reduce the DPT tax benefit to the extent to which the amount included in assessable income as mentioned in paragraph (6)(b):

                     (a)  would not have been so included if the scheme had not been entered into or carried out; and

                     (b)  is directly referable to the DPT tax benefit.

[CFCs]