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Commentary

D8.117 Dividend distributions

Corporate tax

In the case where the total amount available for income allocation is allocated for distribution as dividends, the Tax Acts apply as if the total amount were dividends on shares paid on the distribution date by the authorised investment fund to the participants in proportion to their rights1. For distributions made on or after 1.30 pm on 27 February 2012, where a corporate investor holds an interest in an AIF which fails the qualifying investment test (D1.788)2 all credits and debits in relation to the relevant holding (including dividend

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