I have a question for anyone out there with experience of Australian tax issues re dividends.
I am a non-resident in Australia. I have tax residency in a country that does not have a double taxation agreement with Australia, so withholding tax on dividends is paid at 30%.
As I understand it, when dividends are paid in Australia to non-residents, franked dividends are not subject to withholding tax. Unfranked dividends are. If those dividends are comprised of income from foreign sources that are paid to an Australian company and onwards to non-residents in the form of dividends, then that is considered conduit foreign income and is exempt from Australian withholding tax.
As Neuren's income, ie progress payments and royalties, is derived exclusively from foreign countries, does this mean that any dividend paid will be exempt from Australian withholding tax?
As a supplementary question, if all of the dividend is derived from conduit foreign income, then would the company necessarily pay a fully franked dividend? I understand that for New Zealand shareholders, franked dividends are nevertheless subject to tax, with no allowance for franking credits. So dividends from NEU would be taxed twice if paid fully franked to a NZ resident shareholder. But there would be no disadvantage that I can see to Australian shareholders who would still pay tax once, whether the dividend is franked or not.
BTW, well done at the cricket. Makes me want to emigrate down under.
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