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The reason div7a is inapplicable is because you declare a dividend and nothing more. Ie it's an ordinary commercial dealing with little to no contrivance. Can it be said that a choice to declare that dividend attracts Part iva?  No you can't because it's a simple choice always available to taxpayers. Like wages or interest on loan or FBT cash out etc etc. You aren't forced by part iva to take the path producing highest tax outcome. If that were the case every single transaction would be part iva because most if not all have a tax impact. the concept of ordinary commercial dealings is invented to prevent such an anomalous outcome. A dividend declaration has no contrivance and is well within that definition accordingly