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  • New Taxpayer Alert about structured arrangements

    We are reviewing certain structured arrangements involving the transfer of shares in the period around the shares’ ex-dividend date. We are concerned these arrangements involve taxpayers inappropriately receiving franking credits in breach of rules designed to maintain the integrity of the imputation system. The arrangements have typically been marketed to investors such as equity funds and large superannuation funds.

    We want to bring this to the attention of SMSF trustees and professionals to help prevent the spread of such arrangements, and so you can make informed decisions.

    Taxpayer Alert 2018/1 is now available to provide further guidance on this matter.

    What are the structured arrangements of concern?

    The arrangements involve an Australian taxpayer with an existing investment in shares acquiring an additional parcel of the same shares. The additional shares are held for a short period over the ex-dividend date, however the taxpayer has nominal or no economic exposure to those additional shares.

    What you need to do

    In the event that you have entered, or are contemplating entering, into an arrangement of this type, we recommend you seek independent professional advice, review your arrangements, and discuss your situation with us by emailing

    Read the full details on our Legal database – TA2018/1 - Structured arrangements that provide imputation benefits on shares acquired on a limited risk basis around ex-dividend dates.

      Last modified: 14 Feb 2018QC 54562