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Paying dividends: The new landscape interaction between s.245T and the income tax provisions paper


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.

Author profile

James Pettigrew ATI
James is a Partner in the Sydney office of Deloitte. He advises on a wide range of corporate tax matters for clients primarily in the finance, infrastructure, property and funds management sectors. He has presented for the Tax Institute and the Institute of Chartered Accountants in Australia, and he has lectured in the University of Sydney Masters Degree Programme. - Current at 06 February 2014
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This was presented at NSW 6th Annual Tax Forum .

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