ato ruling - just out, page-5

Now a big chunk of the cash is going to land up in the ATO's pocket rather than shareholders pockets.
For SMSF
ATO gets 4.92*.15 = 0.738 cents this tax year and
6.26 *.10 when shareholder sells
Shareholder gets 6.26 including the 0.626 cents of tax free loan from the ATO until they sell. Plus 4.18 cents in dividend. Total 10.44 cents with a future tax liability of 0.626cents
Over long run ATO gets 1.36 cents and SMSF holders get 9.82 cents. 12% to the ATO, certainly not a large chunk.

For 40% tax holders
ATO gets 4.92*.4 = 1.97 cents on dividend
and 6.26*.2 = 1.52cents capital gain, which is lent tax free to shareholders until they sell.
3.49cents to tax man, which is 31%.

Tooluck or anyone else have a suggestion on how management could have better returned funds to shareholders?