Subject to this Division, where:
(a) subsection 457(1) applies to a change of residence of a CFC; and
(b) at the residence - change time referred to in that subsection, a person is an attributable taxpayer in relation to the CFC;
the person must keep records (in Australia or elsewhere) containing particulars of:
(c) the acts, transactions and other circumstances that resulted in the person being an attributable taxpayer in relation to the CFC at that time; and
(d) the basis of the calculation of:
(i) the direct attribution interest; and
(ii) the aggregate of the indirect attribution interests;
in the CFC held by the person at that time; and
(e) the basis of the calculation of the attribution percentage of the person in relation to the CFC at that time; and
(f) the basis of the calculation of the amount (including a nil amount) included in the assessable income of the person under section 457 in relation to the change of residence concerned.