The ATO in TR 2012/5 give a ruling on dividends which includes:
From profits (para 3);
From "mce-anchorunrealised capital profit of a permanent character recognised in its accounts and available for distribution" (para 4).
A properly structured TO imho would be able to include capital profits that would be able to be distributed as franked dividends.
http://law.ato.gov.au/atolaw/view.htm?docid="TXR/TR20125/NAT/ATO/00001"
The ATO in TR 2012/5 give a ruling on dividends which includes:...
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