Section GB 15 — Income Tax Act 2007: CFC income or loss: arrangements related to quarterly measurement

GB 15 CFC income or loss: arrangements related to quarterly measurement When this section applies (1) This section applies when— (a) an income interest in a CFC is transferred by a person to an associated person; and (b) the associated persons make an arrangement for making or not making an election under section EX 26(3) (Use of quarterly measurement); and (c) the arrangement has an effect of defeating the intent and application of the international tax rules. Treatment of election (2) The Commissioner may treat the election as having been made or not made, as applicable, to the extent appropriate to prevent the effect of the arrangement. Defined in this Act: arrangement , associated person , CFC , Commissioner , income interest , international tax rules , Compare: 2004 No 35 s GC 10