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You will be denied access to certain credits and concessions in relation to a section 47A deemed dividend if you:
- do not disclose the deemed dividend in your tax return
- do not notify the Tax Office of the deemed dividend within one year of the end of the income year in which the dividend is deemed to have been paid.
The credits and concessions you lose are:
- any credit for foreign taxes you have paid on the dividend
- any possibility that a part of the deemed dividend will be treated as an exempting receipt
- any possibility that a part of the deemed dividend may be treated as exempt from tax as a payment out of the income of a CFC already attributed to you.
The deemed dividend will also not give rise to an attribution credit.
Last modified: 05 Dec 2006QC 17522