Private ruling: Imputation benefits
Date of advice: 16 May 2018
Published: September 2018

Ruling: Q1: Will the Commissioner make a determination under the anti-streaming rule in paragraph 204-30(3)(a) of the ITAA 1997 that a franking debit arises in the franking account of Company in respect of the Special Dividend? | A1: No | Q2: Will the Commissioner make a determination under the franking anti avoidance measure in paragraph 177EA(5)(a) of the ITAA 1936 that a franking debit arises for Company in respect of the Special Dividend? | A2: No Scheme The taxpayer company (Company) is an Australian public company listed on the ASX. During the year it determined and paid a special dividend that was a condition precedent to a takeover scheme of arrangement between the Company and its members effected under section 411 of the Corporations Act 2001 .




Subject: Imputation benefits: In order to protect the privacy and commercial in-confidence components of this private ruling the following summary is provided: