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Edited version of private advice
Authorisation Number: 1051812413758
Date of advice: 26 March 2021
Ruling
Subject: Special dividend payment
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.