Okay so you need to stop thinking of imputation credits as being paid per se. They are notionally allocated to dividends paid and their is no credit as such that's physically paid by the company to the shareholder nor is the credit paid to the IRD. Kind of a "look through" thing, shareholders get the credit on the basis the company has attached the imputation. When a company attaches an imputation credit to a dividend paid their Imputation Credit account is debited. When a company pays tax their ICA account is credited. Its not tax fraud to attach imputation credits you don't have but in practice the penalties that go with that make it uneconomic to run a negative imputation balance in one's company account which is why these companies are pre-paying their taxes.
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