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On 16 April 2014, the ATO issued Taxation Determination TD 2014/8 entitled "Income tax: does a franking credit arise in the franking account of a head company of a consolidated group when a franked distribution is made by an entity that is not a member of the consolidated group to a trust that is a subsidiary member of the consolidated group?"

The answer given to the question posed is:

"Yes. Provided the head company is entitled to a tax offset under Division 207 of the Income Tax Assessment Act 1997 (ITAA 1997)1 because of the franked distribution and satisfies the residency requirement for the income year in which the distribution is made, a franking credit will arise in the head company's franking account on the day on which the distribution is made."

It was previously released in draft form as TD 2013/D10.

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