PCG 2024/D4 contains the ATO’s compliance approach to the application of section 207-159 which was introduced in November 2023 and applies to make certain corporate distributions unfrankable where they are funded by an issue of equity interests. We made a submission to the ATO outlining the need for certain binding technical interpretations about the application of the provision as well as seeking further ‘low-risk’ examples for private companies to cover arrangements that are explicable by non-tax considerations such as asset protection.
You can read our submission below
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