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Unfrankable Distributions from Share Capital Account: A distribution is unfrankable if it is sourced, directly or indirectly, from a company’s share capital account. 3 This applies to distributions that constitute a reduction or return of share capital, even if labelled as a dividend. 4 The definition of a share capital account includes an account a company keeps of its share capital, or any other account where the first amount credited was share capital. 5 Therefore, any portion of a selective buyback that is a return of share capital cannot be franked.
Benchmark Franking Percentage: A corporate tax entity franks a distribution by allocating a franking credit to it. 6 The benchmark franking percentage is a key concept in determining the maximum franking without penalty. If an entity franks a frankable distribution at a percentage that exceeds its benchmark franking percentage for the franking period, it is liable to pay over-franking tax. 7 This effectively sets the benchmark franking percentage as the maximum franking allowed without incurring a penalty.
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If a trustee has a power to change the beneficiaries under a trust and exercises that power, does it cause a CGT event to occur?
In Short: A trustee's valid exercise of a power to change beneficiaries under a trust generally does not cause a Capital Gains Tax (CGT) event to occur, specifically CGT events E1 or E2, unless the change terminates the existing trust and creates a new one, or causes an asset to be held under a separate charter of obligations.
Relevant Legislation: Income Tax Assessment Act 1997 (Cth), s 104-5 — provides a summary of CGT events, including E1, E2, E5, E6, E7, E8, and A1.
Relevant Case Law and Ruling: TR 2018/6 — confirms that amending a trust's vesting date through a valid exercise of power in a trust deed or court approval does not trigger CGT event E1.
CGT Events E1 and E2: A change in the terms of a trust, including the addition or exclusion of beneficiaries, pursuant to a valid exercise of a power in the trust deed, will generally not cause CGT event E1 or E2 to happen.
CGT Event E5: CGT event E5 occurs if a beneficiary becomes absolutely entitled to a CGT asset of a trust as against the trustee. For a beneficiary to be absolutely entitled, they must have a vested and indefeasible interest in the entire trust asset and the right to call for its transfer.
CGT Events E6 and E7: CGT event E6 happens if a trustee disposes of a CGT asset to a beneficiary in satisfaction of an income right, and E7 happens for a capital right.
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ATO rulings are a critical source of authority for Australian tax positions, but they are notoriously difficult to search — there are thousands of them, across eight ruling types, and the keyword search on ato.gov.au assumes you already know the ruling number. Cyter Tax makes the entire ruling library searchable by concept.
When you ask a question, Cyter generates a query embedding and performs semantic similarity search across the ruling corpus. This means a question about "when a trust UPE becomes a loan" will surface TR 2010/3, TD 2022/11, PS LA 2010/4 and PCG 2017/13 even if none of them contain the exact phrase "UPE becomes a loan". The AI understands conceptual equivalence, not just keyword overlap.
Results are ranked by relevance, filtered to the corpus types you have enabled, and presented with verbatim quotes from the ruling paragraphs Cyter relied on. You can narrow to specific ruling types (e.g., TR only, or PS LA only) using the corpus filters.
Not all ATO rulings bind the Commissioner. Public binding rulings (TR, TD, GSTR, MT, LCR) bind the Commissioner for taxpayers who rely on them in good faith. PCGs and PS LAs do not bind, but are indicative of how the ATO will administer the law. Cyter's responses preserve this distinction — when citing a PCG or PS LA, the response notes the non-binding status.
For a specific taxpayer's position, a private binding ruling is usually the safest path. Cyter can help you prepare the legal and factual research underpinning a private ruling request, but applying for the ruling itself remains a separate process.
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