Section GB 7 — Income Tax Act 2007: Arrangements involving CFC control interests

GB 7 Arrangements involving CFC control interests When this section applies (1) This section applies when— (a) 2 or more persons who are New Zealand residents enter into an arrangement; and (b) under the arrangement, a control interest in a foreign company is held by another person; and (c) a purpose of the arrangement is to prevent the foreign company being a controlled foreign company (CFC). Interest treated as held by residents (2) The control interest is treated as being held by the New Zealand residents in equal proportions, for the purposes of determining whether the company is a CFC. Defined in this Act: arrangement , CFC , control interest , foreign company , New Zealand resident , Compare: 2004 No 35 s GC 7