In November 2023, legislation introducing a new integrity rule became law.
New section 207-159 of the Income Tax Assessment Act 1997 will make certain corporate distributions made on or after 28 November 2023 unfrankable where they are funded by capital raising.
Pitcher Partners previously made a submission to Treasury on this measure when it was first released for public comment as exposure draft legislation where some of our submissions were adopted by the Government.
The ATO is now consulting about what advice and guidance it should provide in relation to this new measure.
Pitcher Partners made a submission to the ATO outlining the key areas of concern that the new measure raises for private companies in particular. We will continue to engage with the ATO to seek appropriate outcomes for middle market taxpayers.
You can read our submission below.
