Income Tax Act 2007

Deductions - Attributed losses from foreign equity

DN 1: Attributed controlled foreign company loss

You could also call this:

“Deductions for losses from foreign companies you control”

You can get a deduction for a loss from an attributed controlled foreign company (CFC). However, there’s a rule called the jurisdictional ring-fencing rule that affects this. You can find more information about this rule in section DN 4.

This rule adds to the general permission and overrides the capital limitation. The other general limitations still apply to this deduction.

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View the original legislation for this page at https://legislation.govt.nz/act/public/1986/0120/latest/link.aspx?id=DLM1513894.

Topics:
Money and consumer rights > Taxes

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“Rules for when you can claim a loss from a foreign company you control”

Part D Deductions
Attributed losses from foreign equity

DN 1Attributed controlled foreign company loss

  1. A person is allowed a deduction for an attributed controlled foreign company (CFC) loss, subject to the jurisdictional ring-fencing rule in section DN 4.

  2. This section supplements the general permission and overrides the capital limitation. The other general limitations still apply.

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