4.12.2.10 Attribution Percentages
Date of effect
This topic has effect to controlled private trusts and controlled private companies from 1 January 2002.
In this topic
This topic contains the following information:
- summary, and
- determining attribution percentages.
Summary
Attribution of the assets (1.1.A.290) and income of controlled private trusts and controlled private companies should be determined according to the individual/s, or members of a couple (1.1.M.120) who control the structure.
When making a decision as to the percentage of attribution of a structure to a stakeholder, the delegate MUST refer to the relevant (attribution) decision making principles.
Act reference: SSAct section 1207X Attributable stakeholder, asset attribution percentage and income attribution percentage, section 1207V Controlled private trusts, section 1207Q Controlled private companies, section 1209E Decision-making principles, section 4(2) Member of a couple-general, section 8(1)-'income'
Social Security (Attributable Stakeholders and Attribution Percentages) Principles 2017
Social Security (Attribution of Assets) Principles 2017
Social Security (Attribution of Income) Principles 2017
Policy reference: SS Guide 4.12.1.20 Determining a Controlled Private Trust from 01/01/2002, 4.12.1.30 Determining a Controlled Private Company from 01/01/2002
Attribution percentages
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:
If the individual/s is/are…. | Then…. |
---|---|
a sole attributable stakeholder of a controlled private company or controlled private trust (other than a concessional primary production trust), | attribute 100% of the assets AND income of the structure to the sole attributable stakeholder. |
members of a couple who are the ONLY attributable stakeholders of a controlled private company or a controlled private trust (other than a concessional primary production trust), | attribute 100% of the assets AND income of the structure to the couple (in the percentage determined by the level of control exhibited by each member of the couple). |
multiple stakeholders of a controlled private company or a controlled private trust (other than a concessional primary production trust), |
attribute the assets AND income of the structure to the stakeholders in the percentage determined by the level of control exhibited by the individuals. Example: 2 persons with control powers = 50% each 3 persons with control powers = 33.33% each. (Although unusual the percentage need not be an equal amount, e.g. 60/40%). |
Exception: The delegate may determine that the attribution percentage of an individual may be reduced to any percentage lower than 100%, including 0%.
Example: Where the trust is a concessional primary production trust.
Note: 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.
Note: See 4.12.7 for information on the treatment of the income and distributions of a private trust or private company.
Act reference: SSAct section 1208U Concessional primary production trusts
Policy reference: SS Guide 4.12.11.20 Qualification provisions for the primary production concession