Finalisation of ATO compliance approach for capital raised for the purpose of funding franked distributions PCG

The finalised guideline is broadly in line with the draft version, however there are some areas that the final PCG does not address, as outlined by Stephen Carpenter, Hannah Hesse, Stacey Hannam and Julia Klarich.

The Australian Taxation Office (ATO) released Practical Compliance Guideline (PCG) 2025/3 "Capital raised for the purpose of funding franked distributions – ATO compliance approach" on 24 September 2025. The finalised PCG is broadly in line with the draft version (PCG 2024/D4) released in December 2024 and sets out the ATO's risk assessment framework and its compliance approach to considering the application of section 207-159 of the Income Tax Assessment Act 1997 (ITAA 1997). There a...

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Authors: Stephen Carpenter, Hannah Hesse,

Stacey Hannam
, Julia Klarich

Published Date: 25 September 2025

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