Section EX 14 — Income Tax Act 2007: Attribution: 10% threshold, not PIE
Text of the provision Official document
EX 14 Attribution: 10% threshold, not PIE Persons with attributed CFC income or loss (1) A person has attributed CFC income or loss from a CFC only if the person— (a) has an income interest in the CFC of 10% or more for the relevant accounting period; and (b) is not a portfolio investment entity. Portfolio investment entity (2) A portfolio investment entity that would have attributed CFC income or loss from a CFC in the absence of subsection (1)(b) has FIF income or loss from the CFC under the FIF rules. Defined in this Act: accounting period , attributed CFC income , CFC , FIF income , FIF rules , income interest , loss , PIE , portfolio investment entity Section EX 14: replaced (with effect on 1 July 2011 and applying for income years beginning on or after that date), on 7 May 2012, by section 18(1) of the Taxation (International Investment and Remedial Matters) Act 2012 (2012 No 34).
Official source: legislation.govt.nz
Search case law on this topic
See judgments from New Zealand courts and tribunals with a plain-English summary and legal holding.
Explore case law →