Australia's controlled foreign company regime

Under Australia's controlled foreign company (CFC) regime, enacted in 1990, certain types of income derived by foreign companies which are "controlled" or deemed to be controlled by Australian residents are taxable in their hands even though the income has not been repatriated. This article describes the key features of Australia's CFC regime and considers various aspects of the regime, including the definition of CFC, attributable income, exemptions from the CFC regime, and relief provisions. The article also discusses the proposed changes to the CFC regime.