Attribution Percentage

Summary of attribution percentage

Attribution of the assets and income of controlled private trusts and controlled private companies should be determined with reference to the individual(s), or members of a couple who control the structure.    

When making a decision as to the percentage of a structure to attribute to a stakeholder, the delegate must refer to the relevant (attribution) decision-making principles.    

In summary, the delegate is required to consider:

• circumstances affecting the relationship with the company or trust,
• contribution to the company or trust,
• past benefit from distributions by the trust or company,
• future benefit from distributions by the company or trust,
• other benefit from the assets and income of the company or trust,
• any existing attribution for other companies or trusts.    
  More →

  Legislation Library - Commission Determinations

  Attribution of Assets – Principles 2001

  Attributable Stakeholders and Attribution Percentages – Principles 05022001

  Attribution of Income – Principles 2002

  More → (go back)

Attribution percentage – different categories of involvement

When determining the attribution percentage to an individual(s) of a controlled private trust or controlled private company the assessor should also have regard to the following:

Delegate discretion to determine lower attribution amount

The delegate, however, may determine that the attribution percentage of an individual may be reduced to any percentage lower than 100%, including 0%, for example, where the trust is a concessional primary production trust. Note that in some rare situations or situations involving primary production concessions, an attributable stakeholder's asset attribution percentage and income attribution percentage need not be the same percentage.