(1) For other entities, the fact that all or part of the franking credit on a distribution is also a venture capital credit can be ignored.
(2) The franking credit will either generate a gross - up of the entity's assessable income and a corresponding tax offset under Division 207 or, if the right to make an election under section 124ZM of the Income Tax Assessment 1936 is exercised, the franked part of the distribution will be treated as exempt income.
(3) The unfranked part of the distribution is treated as exempt
income under section 124ZM of the Income Tax Assessment Act 1936 .