The domicile of a company depends on the location of its central management and the majoity of its voting power. Although Neuren is incorporated in NZ, the taxman would definitely argue it is an AU corporation.
There is a double tax treaty between NZ and AUS. I believe NZ has a similar franking system. NZ companies can attached both franking credits from NZ and AU to their dividends. Not 100% sure, but I think it works the same the other way around.
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