This paper examines the dividend and franking implications of the 2010 amendments to s254T of the Corporations Act 2001 and the consequential amendments that were made to the tax legislation, together with the proposed “refinements” to those measures.
The focus of the paper is on:
- the new concept of “dividend” for Corporations Act purposes
- the impact of the legislative reforms on the tax concept of “dividend” and the franking of dividends
- the Commissioner’s views
- the potential impact of the future reforms.