The purpose of the franking system was / is to prevent double taxation of company profits.
When a taxpayer has no other tax to offset and hence gets the rebate, this causes that portion of the companies profit to be not taxed at all.
This was a change little johnnie made that one could argue was against the spirit of the original legislation.
Thats my 2 cents ...
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Ann: Update - Dividend/Distribution - TLS, page-13
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