certain preference shares. This is the "holding period rule". Shares must be "at risk" for the necessary period, i.e. not with an offsetting derivatives position for instance. Or who Has total franking credits for the tax year of less than $5000 (the "small shareholder exemption") and has not arranged to pass-on the benefits to someone else (the "related payments rule"). Thus franking credits are not available to short-term traders, only to longer term holders, but with small holders exempted provided it's for their own benefit. The small shareholder exemption is not a "first $5000", but rather once the $5000 threshold is passed the rule is inoperative and all one's shares are under the holding period rule. For the holding period rule, parcels of shares bought and sold at different times are reckoned on a "first in, last out" basis. Each sale is taken to be of the most recently purchased shares. This prevents a taxpayer buying just before a dividend, selling just after, and asserting it was older shares sold (to try to fulfill the holding period). This "first in, last out" reckoning may be contrasted with capital gains tax. For capital gains the shareholder can nominate what parcel was sold from among those bought at different times. Company shareholders A dividend received by a company shareholder is income of the receiving company, but the dividend income is not grossed-up for the franking credit nor is the receiving company entitled to claim the franking credit as a tax credit. Instead, the franking credit is added directly to the receiving company's franking account, and can be paid out in the same way as franking credits generated by the receiving company. This transfer of credits has made the previous "intercorporate rebates" allowances redundant. Those rebates had avoided double taxation on dividends paid from one company to another company. Those rebates were part of the original 1936 Taxation Act (section 46), meaning that the principle of eliminating double taxation has been present to some degree in Australian income tax law for a very long time. The company tax rate has changed a few times since the introduction of dividend imputation. In each case transitional rules have been made to maintain the principle of reversing the original tax paid, even if the tax rate has changed. This has been either by separate franking accounts for separate rates (e.g. class A 39%, class B 33%),