Ann: Allkem and Livent to merge - presentation, page-240

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Don93

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908

13/05/23

07:38

Post #: 67754411
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Originally posted by jm3767: ↑

This is how I understand it works ... please correct me if I am wrong.

Newco will no doubt pay Aust Income Tax at Aust Corporate rates on profits attributed in accounts to Australian based operations and have possible franking credits.

Profits will then be transferred to to US parent and US tax paid on Total Consolidated Profits, but US Tax Office will give credits for any foreign tax already paid, so no double taxation.

Newco will distribute (part of) profits after tax to shareholders and US witholding tax (15%) will be deducted and go into US tax coffers.

Australian shareholders will declare the net dividend received + US withholding tax in their taxable income.
ATO will give a Foreign Tax Paid Offset equal to US with-holding tax paid towards any Aust Tax liability.
The offset is NON refundable, so if it is more than any tax payable ... the excess amount is lost (eg if you have a low taxable income and incur little or no tax).
So there is NO double taxation of anything.
However, I think tthe franking credits just ‘disappear’ (effectively into coffers of ATO) in this situation, unlike the situation if Newco was Aust domiciled in which case the franking credits would be distributed along with dividends to Aust & NZ shareholders to whom they are a 100% REFUNDABLE, tax credit.
Of course, Aust franking credits have zero value to other (ie non Aus or NZ) shareholders.

So, net effect appears to me to be that low paying or zero taxpaying shareholders such as smsf in pension mode will be worse off as there will be no franking credits.
To what extent future dividends would have been franked if AKE carried on as an Aust company, who knows, but as much of income would have been derived offshore, it probably be far,far less than 100%

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I understand everything you are saying, but I do feel there is still double taxation in there - not at Company level, but at personal level.

NewCo will pay US income tax and if they are unable to pass any of that tax they have paid onto the shareholder (through franking credits) I don’t see how the shareholder then isn’t paying tax on Company profits that have already been taxed in the US.

AKE Price at posting: $15.14 Sentiment: Buy Disclosure: Held
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Ann: Allkem and Livent to merge - presentation, page-240

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