Correct. A credit is a credit is a credit and if it is surplus to what taxation is due on one's total taxable income, then it should be refunded. To treat it as a tax credit to those who have tax owing but not to treat is the same way for those without outstanding tax liabilities is contrary to all good policy outcomes. You can't change the status of the credit and create two classes of tax payers.
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Franking Credits - Brilliant article, page-38
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