What you're saying is they can't declare and pay a partially franked dividend until they've paid the tax.
Let's pretend you're right and they paid FY22 tax by 1 December 2022. Seems crazy to pay an unfranked dividend on 19 September 2022, instead of waiting until 2 December 2022 to pay a franked dividend.
What I'm saying is if they were a taxpayer for FY22, they should've been able at least partially frank the September 2022 dividend. The franking account would've temporary gone into deficit until they paid the tax during FY23.
Probably one to agree to disagree.
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