On 4 December 2024, the Australian Taxation Office issued PCG 2024 / D4 dealing with the ATO’s compliance approach to “capital raised for the purpose of funding franked distributions”.
The Draft PCG sets out a green / low risk zone and a red / high risk zone, and also acknowledges that there is effectively a “grey zone” where an arrangement will not be categorised by the PCG as either low risk or high risk.