Where, at the end of a statutory accounting period (in this Division called the eligible period ) of a company:
(a) the company is a CFC; and
(b) there are one or more attributable taxpayers in relation to the company;
the attributable income of the company (in this Division called the eligible CFC ) for the eligible period is calculated separately for each such attributable taxpayer (in this Division called the eligible taxpayer ) in accordance with this Division.