(1) A corporate tax entity must not frank a distribution from profits with a franking credit that exceeds the maximum amount of income tax that could have been paid, at the entity's corporate tax rate for imputation purposes for the income year in which the distribution is made, on the profits distributed.
(2) If a distribution is franked in excess of this limit, the
entity will be taken to have franked the distribution with the
maximum franking credit for the distribution.