(1) This section applies in calculating the attributable income of the eligible CFC.
(2) Conditions that operate between the eligible CFC and another entity do not satisfy the cross - border test in subsection 815 - 120(3) of the Income Tax Assessment Act 1997 if:
(a) the other entity is a CFC; and
(b) the eligible CFC and the other entity are residents of the same listed country (disregarding section 383 of this Act).