"it is the 0 tax rate in pension phase that is the problem"
Super funds used to have tax in excess of imputed tax credits until 2009: https://www.aph.gov.au/~/media/05%20About%20Parliament/54%20Parliamentary%20Depts/548%20Parliamentary%20Budget%20Office/Publicly%20released%20costings/Dividend%20imputation%20credit%20refunds%20-%20PDF.pdf?la=en from https://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Budget_Office/Publications/Costings but presumably the steady rise of pensions has reduced their tax to below imputed tax credits since that time. The 0 tax rate in pension phase set a time bomb in motion.
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Proposal to abolish refundability of Franking Credits, page-231
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