Ann: Allkem and Livent to merge - presentation, page-241

The concept of Franking credits where taxpayer affectively gets access to / benefits from the corporate income tax the company paid on profits is, afaik, unique to the Aust & NZ tax system.
In that sense, corporate profits end up effectively being taxed at the marginal tax rate of the shareholder (once you take into account the flowback of franking credits).
What you have identified is really the crux of the big debate in Aust over personal taxation and franking credit system, esp when applied people / entities who have minimal tax liabilities such as super funds (esp smsf) in pension mode.....When you take into account the full refund of franking credits, it amounts to effectively zero tax being collected by govt on the ‘corporate profit from which THAT SHAREHOLDER’s dividend payment was derived.
I am not arguing for/against the div imputation / franking credit system, but it does appear to confer advantages to Aust/NZ shareholders of Aust/NZ companies with respect to taxation of divs compared to other domiciled companies.
Different scenario is company does not distribute profits as divs, but reftains them to ‘grow the company’ or uses other mechanisms such as buybacks, bonus shares etc.
In that context, I do not think Apple Computer has paid many or any dividends during its corporate life, but its share value has grown massively.
So one needs to consider Total Shareholder Return and does one want cash in hand dividends, or get a ‘cash flow’ if needed for a retirement income by ‘pruning off’ and selling the growth each year ... which would be taxed at CGT rates.