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Legislation
ATO documents that consider ITAA 1936 s Special Dividend 55 Assessability of the Special Dividend 60 Residents 60 Non-residents carrying on a business at or through a permanent establishment 62 Non-residents not carrying on a business at or through a permanent establishment 66 Gross-up and tax offset 71 Qualified persons 75 Related payments rule 79 Primary qualification period 82 Holding period rule 86 Refundable tax offset 92 Exempting entity 95 Return of Capital 98 Return of Capital is not a dividend 98 Capital gains tax consequences 105 CGT event G1 105 CGT event C2 111 Discount capital gain 116 Foreign shareholders are able to disregard capital gains tax 118 Anti-avoidance provisions 123 Application of sections 45A, 45B and 45C