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Use of the gross up and tax offset mechanism is denied if the distribution is made to a person that is not a qualified person.

Use of the gross up and tax offset mechanism is denied if the distribution is made to a person that is not a qualified person. What is a qualified person?

A shareholder that holds the shares at least 45 days or 90 days for preference shares.

An Australian Resident taxpayer.

A shareholder that holder shares for at least 12 months.

A trust.

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