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13.3.7. Attributable Taxpayer

For the attributable income of a CFC to be included in the taxable income of a company, that company must be an attributable taxpayer in relation to that CFC. To satisfy this test, the company, together with its associates, must have:

  • at least a 10% control interest in the CFC; or
  • at least a 1% control interest in the CFC and be one of five or fewer entities controlling the CFC.