(1) Each of the following is an attribution account entity:
(a) a company that is not a Part X Australian resident;
(b) a partnership;
(c) a trust.
(a) a company ceases to be resident in an unlisted country and becomes a Part X Australian resident; and
(b) a taxpayer is an attributable taxpayer in relation to the company immediately before the time of the change of residence;
in determining whether an attribution debit arises for the company in relation to the taxpayer in respect of an attribution account payment made to the taxpayer or another attribution account entity, the company is taken to be an attribution account entity.