Taxation Determination

TD 94/27W

Income tax: does 'separate net income' include the imputation credits attached to franked dividends?

  • Please note that the PDF version is the authorised version of this ruling.
    TD 94/27 has been withdrawn as part of a project to review public rulings.
    This document has changed over time. View its history.

Notice of Withdrawal

Taxation Determination TD 94/27 is withdrawn with effect from today.

1. TD 94/27 concluded that imputation credits are not included in 'separate net income' as defined in section 159J of the Income Tax Assessment Act 1936.

2. Section 159J has been replaced with Subdivision 961-A of the Income Tax Assessment Act 1997. The concept of 'separate net income' has been replaced with 'adjusted taxable income for offsets'.

3. TD 94/27 has no ongoing relevance, and is withdrawn without replacement.

Commissioner of Taxation
27 June 2018


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ATO references:
NO 1-D75OWX3

ISSN: 2205-6211

Related Rulings/Determinations:

IT 2391

Subject References:
imputation system;
dependant spouse rebate;
separate net income

Legislative References:
ITAA 159J,

TD 94/27W history
  Date: Version: Change:
  14 April 1994 Original ruling  
  29 November 2006 Original ruling + note Repeal provision note
You are here 27 June 2018 Withdrawn