This session provides an overview of topical anti-avoidance measures related to distributions and franking credits, including ATO activity.
- Section 207-145, franking credit policy and government intended “wastage” of franking credits.
- Equity funded distributions, s 207-159 and PCG 2025/3;
- The Merchant litigation (dividend stripping);
- The qualified person rules (45-day rule), section 177EA and ATO compliance activity (including the ATO PCG);
- The Lerna litigation (s45B); and
- Practical and worked examples.