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Can we frank that dividend? presentation

Published on 30 Oct 12 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

There is a long and onerous list of obstacles facing companies looking to answer this most fundamental of questions under the Australian imputation system. The last 12 months has seen some significant developments which impact on the answer. This presentation looks at where we currently stand in relation to:

  • the requirement for “profit” and the ATO’s views in Taxation Ruling TR2012/5
  • treasury’s on–going review of the Corporations Law test for the payment of dividends
  • the Consolidated Media decision and the dividend component of a share buy–back
  • the Mills decision and the application of section 177EA
  • the many class rulings on pre–sale dividends and the “45 day” rule.

Author profiles:

Author Photo - Wayne Plummer ATI
Wayne Plummer ATI
Wayne is a Tax Partner at PwC with over 28 years of corporate tax experience. He advises a range of multinational companies in relation to their Australian tax affairs. Wayne specialises in the tax consolidation rules, capital management and M&A. He is a regular tax presenter and contributor to ATO and Treasury consultation forums. Current at 02 June 2015 Click here to expand/collapse more articles by Wayne PLUMMER.
 
Michelle Hogg
Michelle is a Director at PwC. Current at 30 October 2012

This was presented at 2012 Corporate Tax Masterclass.

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