Corporate tax cuts and franking, start-ups and funding of growth - the 26th Noosa Tax Intensive


Turning a client’s start-up into a success and getting it to the point where it is generating taxable income is a huge challenge, and many don’t even make it that far.

For those that do, they then need to prepare for the anomalous outcomes of the recent corporate tax cuts and the flow-on franking implications.

At the 26th Noosa Tax Intensive in November, Robyn Jacobson, CTA (TaxBanter) looks at a number of legislative amendments, some of which have just cleared Parliament, and the now far more complicated process of determining a company’s tax rate and its franking rate in the session ‘Navigating your way through the mist of the corporate tax cuts’.

Following Robyn’s session, Hannah Soh, CTA (Deloitte) expands on some of these issues in the workshop ‘Corporate tax cuts and franking, start-ups and funding of growth’.

We speak to Robyn and Hannah about what to expect in this post.

Robyn told us said “Policy changes, draft ATO rulings and unenacted measures have resulted in significant complexity and uncertainty for businesses. I’ll be taking delegates through the enacted and new measures that determine a company’s tax rate and franking rate.


Robyn’s session looks at the intricacies, nuances and subtleties involved in reducing the corporate tax rate, the meaning of “base rate entity”, “corporate tax rate for imputation purposes” and “base rate entity passive income”, and associated interpretive issues, and the significance of TR 2017/D7 when determining eligibility for the lower tax rate in current and prior income years.

She will also cover the complex treatment of amounts flowing through chains of trusts and partnerships, and what’s involved in working out a company’s franking rate, including dividend strategies.

Robyn said “My aim is to walk delegates through this maze, provide practical information on how to work out if a company is eligible for the lower tax rate and identify the anomalies that are likely to result from the latest changes. I’ll also be providing some ready reckoner tables.”

Delegates will come away with an accurate understanding of how to determine a company’s tax rate and franking rate. I’ll also be providing practical tips and technical insights based on my many interactions and discussions with Treasury and the ATO regarding these measures over the past 18 months.”

Following Robyn’s session, Hannah Soh, CTA (Deloitte) facilitates the workshop ‘Corporate tax cuts and franking, start-ups and funding of growth’ which looks in detail at these changes to the corporate tax rate and franking implications. The workshop also covers structuring issues and protecting IP – topics covered in plenaries one and two on day one of the Intensive, presented by Ian Burgess, CTA (EY) and Clint Harding, CTA (Arnold Bloch Leibler) respectively.

Hannah said, “As always with the Noosa conference, delegates can expect practical, real-life case studies that help them gain a deeper understanding of the materials presented in the plenaries.”

Hannah Soh, CTA
The case studies in the workshop will look at the concept of “base rate entity” and “base rate entity passive income” and associated interpretive issues, and strategies for corporate beneficiaries and accessing trapped franking credits. They will cover issues for start-ups, including ESIC eligibility, ESS and other remuneration strategies, equity raising, and structuring and restructuring considerations. Finally, they will look at IP and how advisers can identify and optimise structures for both protection and access to available grants and concessions, and consider some of the key tax issues associated with IP during the life cycle of a business.

“The more you know, the better the adviser you’ll be. Personally, I find the workshop format a fantastic forum for delegates to tease out the issues that are most relevant to them and their clients”, she continued.

Joining Hannah are workshop leaders Adam Alexander, CTA (Grant Thornton), Corey Beat, CTA (RSM Australia), Simon Bowden, CTA (Clayton Utz), Paul Lyon, ATI (EY), Melinda Peters, CTA (McCullough Robertson), Kim Reynolds, CTA (Vincents), and Murray Shume (Cooper Grace Ward Lawyers).

Hannah is a Partner in the Tax group at Deloitte Private in Sydney. She provides practical tax consulting, planning, compliance and advisory services to a wide range of middle market clients. Hannah is a Chartered Tax Adviser (CTA), a Chartered Accountant with a Masters of Taxation from UNSW, and is a current member of The Tax Institute’s Women in Tax Committee and the NSW Professional Development Committee.

Robyn Jacobson, CTA
Robyn has a background in public practice, and has been a professional tax trainer for 21 years, the last seven years with TaxBanter. A Chartered Tax Adviser (CTA), CA, FCPA, and a Registered Tax Agent, she is currently a member of three Tax Institute committees, and a Deputy Chair of CPA Australia’s Victorian Public Practice Committee. Her advocacy roles include consulting to The Treasury and the ATO on technical issues, including the current Single Touch Payroll Consultation.

The 26th Noosa Tax Intensive takes place 15-16 November, at Sofitel Noosa Pacific Resort. This year’s event focuses on your client’s growth journey, and how to ensure you’ve got the mix of ingredients for success just right. 

Find out more about Robyn’s session, the workshop, and the rest of the program on our website.

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