The Australian Taxation Office (ATO) has issued Taxation Determination (TD) 2019/8 - Income tax: in the definition of 'financial intermediary business' what is meant by 'a business whose income is principally derived from the lending of money'? TD 2019/8 is in relation to the application of the active income test under the controlled foreign companies (CFC) rules, which includes that Australian financial institution (AFI) subsidiaries are able to exclude their 'tainted interest income' from their 'passive income' if their sole or principal business is a financial intermediary business.  A financial intermediary business is defined as, inter alia, a business whose income...