Certain exemptions provided for non-portfolio dividends (10% or more); 1) sale of a CFC interest. Further, where CFCs are located in a listed country (US, UK, Canada, France, Germany, NZ, Japan) only particular types of income (referred to as Eligible Designated Concession Income) is attributable to the Australian controller. 2) There is also an AFI subsidiary exemption which enables interest and certain asset and currency transactions to be exempt for CFCs that are subsidiaries of a registered Australian AFI (may be broader than Australian banks).