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Consultation Paper: Reform of the Controlled Foreign Company Rules


Tuesday, 5 January 2010

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On 5 January 2010, the Assistant Treasurer announced the release of a consultation paper entitled: Reform of the Controlled Foreign Company Rules.

The reform of the controlled foreign company (CFC) rules was announced in the 2009-10 Budget as part of wider reforms to Australia's foreign source income anti-tax deferral attribution rules. The remaining reforms repeal the foreign investment fund (FIF) and deemed present entitlement (DPE) rules and modernise the transferor trust rules.

This consultation paper has been prepared to elicit comment on the high-level design of the taxation laws that will reform the CFC rules.

Draft legislation that gives effect to the decision to repeal the FIF and DPE rules was released for public comment on 18 December 2009.

Remaining reforms to the transferor trust and the anti-roll-up rules are still being developed. Details of these reforms will be issued for comment before the legislation is finalised.

Making a submission

Interested parties are invited to comment on the paper. While submissions may be lodged electronically or by post, electronic lodgement is preferred. For accessibility reasons, please submit responses sent via email in a Word or RTF format. An additional PDF version may also be submitted.

All information (including name and address details) contained in submissions will be made available to the public on the Treasury website unless you indicate that you would like all or part of your submission to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence should provide this information marked as such in a separate attachment. Legal requirements, such as those imposed by the Freedom of Information Act 1982, may affect the confidentiality of your submission.

Closing date for submissions: Monday, 1 March 2010

Address written submissions to:
Attribution Review Unit
International Tax and Treaties Division
The Treasury
Langton Crescent

Fax: 6263 4352

Email: fsiattribution@treasury.gov.au

For enquiries, please call John Nagle (02) 6263 4461 or Peter Peters (02) 6263 2969.

Documents Available:

Acrobat (PDF) documents

 Acrobat (PDF)

Consultation Paper: Reform of the Controlled Foreign Company Rules  135.35kb

Microsoft Word (RTF) documents

 Microsoft Word (RTF)

Consultation Paper: Reform of the Controlled Foreign Company Rules  6,180.37kb

Related Items:

Submissions: Reform of the Controlled Foreign Company Rules - 4/05/2010

Treasury received twenty submissions in response to its consultation paper, 'Reform of the controlled foreign company rules'. Seventeen of these are public submissions and three are confidential. The public submissions are listed below and are accessible by selecting the author.

The opinions expressed in the submissions are those of the authors and do not necessarily reflect the views of the Government or the Treasury.

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