Private ruling: Special dividend payment
Date of advice: 26 March 2021
Published: May 2021

Ruling: The Commissioner issued a private binding ruling in relation to a special dividend payment. The Commissioner considered the application of several provisions including subsection 6(1), subsection 44(1) and paragraph 177EA(5)(b) of the Income Tax Assessment Act 1936 and sections 202-40, 204-30, 207-20, 207-145 of the Income Tax Assessment Act 1997 (ITAA 1997). These provisions are concerned with the assessability of the special dividend, franking credits, tax offsets and anti-avoidance.