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Edited version of your written advice
Authorisation Number: 1051511036824
Date of advice: 03 May 2019
Ruling
Subject: Frankable distribution
The Commissioner made a private ruling that a dividend to be paid by a overseas franking company will be a frankable distribution within the meaning of section 202-40 of the Income Tax Assessment Act 1997 and not unfrankable under paragraph 202-45(e) of the Income Tax Assessment Act 1997.