Cyter Tax is a tax AI trained on Australian statutes, ATO rulings and case law. Every answer is cited and traceable — verified, not hallucinated.
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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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Cyter Tax comes pre-loaded with every major piece of Australian tax legislation, the full library of ATO rulings across all 8 ruling types, and a comprehensive database of Federal Court, High Court, and AAT tax decisions.
Need to add your own internal memos, prior advice, or client documents? Upload them and Cyter indexes them alongside the official corpus — searchable in the same query.
"Tax AI" can mean two very different things. A general-purpose chatbot that has read some tax content alongside the rest of the internet. Or a purpose-built research tool, trained specifically on tax law, that cites every claim back to a primary source. Cyter is the second kind.
Ask a general AI a tax question and you will often get a confident answer that sounds right. The problem is that tax law is a domain where precision is non-negotiable. The wrong section number, an outdated ruling, or a hallucinated case citation can cost a client thousands of dollars and your professional reputation. General models are trained to sound fluent — not to be technically correct on Australian tax.
Cyter is built differently. Every Cyter answer is grounded in a search of the Australian tax corpus first, and the response is then constrained to cite the specific source paragraphs it found. If Cyter cannot find a source, it tells you so rather than inventing one.
Cyter is used by Australian tax accountants, tax lawyers, tax agents, financial advisors and in-house tax teams. The common thread is that the work involves taking a question — from a client, a partner, the ATO, or a court — and producing a defensible written answer with citations to authority.
For an accountant, that might be a Division 7A question on a private company loan. For a tax lawyer, a Part IVA analysis on a restructure. For a tax agent, a small business CGT concession test. For an in-house tax team, a GST treatment for a new product. The workflow is the same: ask, get cited answer, verify, write up.
Trust comes from being able to verify. In Cyter, every footnote in a response links back to the exact statute section, ruling paragraph or judgement paragraph it draws from, with the verbatim source quote shown on hover. You can audit every claim before you put your name to it.
This matters because professional advice, ATO submissions, client letters and court documents all eventually need a human signature. Cyter compresses the research phase from hours to minutes — but the senior reviewer still owns the judgement call. We designed the tool around that reality.
You can try Cyter free with 5 queries on the full Australian tax corpus — no credit card required. Paid plans start where the queries do; firms with multiple users can request a licence with shared usage.
Try Cyter Tax free with 5 queries on the full Australian tax corpus.
No credit card required. 5 free queries to try it out.