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OB 39: ICA transfer for net foreign attributed income
or “Removed: Rules for transferring money related to foreign income no longer apply”

You could also call this:

“Personal services income attribution can affect a company's tax credits”

You have an ICA company. This company can get a debit in its imputation credit account. This happens when there’s an attribution for personal services. The debit amount is the same as the credit amount under section OB 16.

This debit is listed in a table called ‘imputation debits’. It’s in row 13, named ‘attribution for personal services’. The matching credit is in another table called ‘imputation credits’. It’s in row 14, also named ‘attribution for personal services’.

The company only gets this debit if it has accounted for an attribution of income under section GB 29. This section is about calculating the attribution rule.

The date of the debit is important. It’s the last day of the tax year that falls in the income year. This is the year when the company accounts for the attribution of income in its financial statements.

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Next up: OB 41: ICA debit for loss of shareholder continuity

or “Company loses tax credit when shareholders change significantly”

Part O Memorandum accounts
Imputation credit accounts (ICA)

OB 40ICA attribution for personal services

  1. An ICA company has an imputation debit for an amount of an attribution for personal services equal to the amount of an imputation credit under section OB 16.

  2. The imputation debit in subsection (1) is referred to in table O2: imputation debits, row 13 (attribution for personal services). The imputation credit in subsection (1) is referred to in table O1: imputation credits, row 14 (attribution for personal services).

  3. A debit under subsection (1) is recorded in the imputation credit account only if the company has accounted for an attribution of income under section GB 29 (Attribution rule: calculation).

  4. The debit date is the last day of the tax year that falls in the income year for which the company accounts in its financial statements for the attribution of income referred to in subsection (3).

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