special dividend 28c + cap return 10c, page-35

a company pays tax at 30% tax rate. when a company earns australian income, they pay this rate. when a dividend is paid and is fully franked, it means that the entire dividend has the tax paid to 30%, and the tax paid by the company is passed onto the individual or fund so as that money is not double taxed. Superfunds only pay 15% tax, therefore the left over 15% is refunded or used to offset other capital gains tax in the superfund...this is a simplistic explanation, but is the basic gist of it. I will not go into grossing up etc etc.