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Should we change the company tax rate?

In most countries company profits are taxed twice. The company pays tax and the after-tax portion is sent to investors as a dividend and is then taxed again as personal income. In Australia, company profits are only taxed once because the shareholder is responsible for the tax on their total share of the company’s profits, not just the dividend they receive in their bank account. Therefore, the shareholder’s personal tax return needs to take into account the pre-paid company tax.

It does this by adding the pre-paid company tax component of the dividend (franking credit) to the personal taxable income of the investor who then pays tax on that larger amount. Shareholders are required to pay tax on income they never received, but the pre-paid company tax becomes a tax credit that can be used to pay that personal tax.

A $100 portion of company profits means that $30 was sent to the ATO as company tax and $70 was sent to the investor as a dividend. But the investor’s taxable income is $100, not $70. That’s why the dividend needs to be “grossed up” - so that it includes the franking credit in the taxable income. If the investor has a marginal tax rate of 45%, they pay $45 tax on that taxable income (and they pay more tax on that $100 company profit than the company did originally), but they can use the pre-paid $30 tax credit to help pay that personal tax bill.

If shareholders have a 30% marginal tax rate their tax bill is $30 which is also their tax credit and they have no more tax to pay. Their dividends are not tax-free; they are tax paid - that’s why it’s called franking - just like pre-paid postage.

If their marginal tax rate is lower than 30%, the tax credit is larger than their tax bill and they get a refund, just like a worker whose employer has paid too much tax on their behalf. It is a tax refund because it comes from the ATO, but it is actually payment of income from the company profit, withheld by the ATO until the investor completed their own tax return, on which no tax is payable.

Franking credits are NOT a refund of tax never paid; they are a refund of income never received.

In fact, it would be more honest if the income derived from Australian shares were quoted as a pre-tax distribution which is the “grossed up” amount - because that is what shareholders pay tax on. That would make comparisons with other investments more valid, because no other investment income arrives with some or all of the personal tax pre-paid.

It would then also be clear that franking credits have the same value of additional income for every shareholder, not just shareholders on low marginal tax rates such as super funds and retirees.

Note that not all company profits are distributed as dividends and not all dividends are paid to Australian shareholders. Importantly, only Australian shareholders can benefit from this additional taxable income. And not all Australian shareholders welcome this additional taxable income - many prefer their investment returns as capital gains in the form of increased share prices.

For Australian investors, franking credits ensure that company profits are taxed only once, and always taxed at the shareholder’s personal marginal tax rate. We could achieve the same result if there were no company tax and all profits were simply distributed to shareholders as taxable income. Changes to the company tax rate would make no difference to the amount of tax collected from Australian shareholders.

Because company tax in Australia is a withholding tax, it ensures that foreign investors always pay tax in Australia at the company tax rate, because it is withheld from their dividends before it is paid. If there were no company tax, foreign investors would pay no tax in Australia.

Changes to the company tax rate would make a large difference to the amount of after-tax profits available to companies for reinvestment and their ability to generate future profits and that may change decisions around the proportion of profits distributed as dividends. Such a change would also change the tax paid by foreign investors in Australia and that may impact the level of foreign investment in Australia.

 

Jon Kalkman is a former Director of the Australian Investors Association. This article is for general information purposes only and does not consider the circumstances of any investor. This article is based on an understanding of the rules at the time of writing and anyone considering changing their circumstances should consult a financial adviser.

 

  •   3 September 2025
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9 Comments
JohnS
September 04, 2025

we need to think of franking credits like PAYG tax from our wages.

With wages, the employer estimates what the tax the employee will be required to pay, and deducts it from the employee's wages. Then, the employee puts in their tax return, and the correct tax is determined. If the employer deducted too much, then there is a refund, if not enough then the employee has to make up the shortfall.

With dividends, the company estimates what the tax the employee will be required to pay (a flat 30%, the corporate tax rate), and deducts it from the shareholder's dividend payment. Then, the shareholder puts in their tax return, and the correct tax is determined. If the company deducted too much, then there is a refund, if not enough then the shareholder has to make up the shortfall.

If you look at imputation this way, then refunding of imputation credits makes total sense

IanD
September 04, 2025

Well said, JohnS. Whenever I hear otherwise intelligent people raging about franking credit refunds, I always ask if they've ever received a tax refund. Pretty soon they've got their hands over ears saying "waa waa I'm not listening franking refunds baaaad". It's an otherwise unassailable argument :)

JohnS
September 05, 2025

We could probably extend the process a bit further.

Instead of making super pensions tax free, tax the income.

BUT

Give the pensioner credit for the tax already paid.

There are two components of a super balance. The money that was contributed from after tax money, and the money which was taxed when it went in and the earnings (at 15%)

The after tax contributions should come back to the pensioner tax free, no problem there

The other component, tax it as income, but treat the 15% tax already paid as an estimate of the tax that the pensioner will eventually paid. Treat it the same as PAYG deductions and as company tax. Treat it as prepaid tax by the pensioner.

The result, given the current tax scales of $18k tax free, next $27k taxed at 15%, next $90k taxed at 30%.

So someone taking a taxable pension, with the 15% treated as prepaid tax will get about $50k and have no extra tax to pay. Less than $50k and you get a tax refund. More than $50k, there will be some tax payable. And you can get the after tax contribution money back tax free.

People will need to have about $1m in super to be responsibly drawing a pension of $50k (and as a couple that could be $100k)

Those with big super balances will draw more and pay tax - as a bonus, the need to limit the amount of pension balances and the additional tax on super over $3m won't be necessary, it will all automatically be taken care of.

You could even "sell" the idea of taxing super in pension mode at 15%, because the pensioner would get the tax paid back when they put in their tax return.

This idea brings PAYG, company tax and super tax under the same principle.

Dudley
September 08, 2025

"Instead of making super pensions tax free, tax the income.":
"This idea brings PAYG, company tax and super tax under the same principle.":

How to incorporate an Age Pension for the capital-less? Means Tested or Universal?

Rod
September 04, 2025

If there were no company tax, foreign investors would pay no tax in Australia.
This statement is incorrect as they would pay withholding tax
• 10% for interest, regardless of whether a tax treaty is in place
• 15% for unfranked dividends and royalties where there is a tax treaty in place
• 30% for unfranked dividends and royalties where there is no tax treaty in place.

Harry
September 05, 2025

Also on the subject of company tax rate is the different rate depending on source of income and company turnover. Unnecessary.

OldbutSane
September 07, 2025

Re JohnS comment. This used to be the system until Costello abolished it. The taxable portion of an income stream was taxable income with a 15% rebate. The way around this, of course, was doing reconstruction strategies to reduce the taxable portion. This used to be difficult as it had to be done by age 65 but now that you can do it to age 75.

Going back to the original concept is one of the easier ways to make the system fairer, along with getting rid of another Costello innovation of not having to convert your super into an income stream ever (again this used to have to be done at age pension age, whether working or not).

Jon Kalkman
September 07, 2025

It’s hard to see what that would achieve. The 15% tax rebate would make an effective tax-free threshold of $65,000 for a super pension withdrawal, when the bottom marginal tax rate is 14% in 2 years time. And that tax-free threshold only applies to the taxable portion of the withdrawal. Even a pension of $100,000 (from a fund worth $2 million) would only have an effective tax rate of 5%.

Larger funds are likely to have more non-concessional contributions and therefore lower taxable proportions and, as you point out,retirees can easily lower their taxable proportions by using a re-contribution strategy up to age 75.

That is a convoluted way of saying the tax arrangements on super fund withdrawals before Costello didn’t collect much tax and would not collect much tax now. That’s why it was easy for Costello to get the political gain for very little fiscal pain. Importantly, no government since that time has wanted to reverse those changes because it would bring in very little tax and would burn a lot of political goodwill.

Loz
September 13, 2025

A good compromise to fix the franking problem would be as follows.

Company tax for large companies 30%
Company tax for medium companies (as now) at 25%
Company tax for small (eg family or single proprietor companies ) 20%

Franking credit on all company tax paid would be passed on at a maximum of 20%.
So for a $100 profit earned by the large company, investors would get $70 plus franking of $20. This would be treated as currently, so $90 is added to your income and $20 tax rebate applies. The ATO gets to keep the remaining $10.
For a medium company the ATO keeps $5 , so you get $75 plus $20 franking and declare $95 income.

And for small companies, all tax paid is available as franking credit. This avoids penalising small enterprises where an individual or family prefer a company structure to a trust or sole trader structure - they still get back all of the tax they paid as a credit on their personal income tax.

This would seem a good compromise. Most investors would accept it, it is simple, similar to the current system, and it would raise a good deal of revenue for the government. It would also encourage investment in small and medium companies over large companies, as investors would receive more of the profit.

 

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