The statement sets out the statutory record keeping requirements necessary to validate distributions of available subscribed capital (ASC). Essentially, it confirms taxpayers must retain sufficient records to substantiate a distribution qualifies as ASC. The onus of proof is on the taxpayer, and the 7-year record keeping requirement does not apply in this case. If the taxpayer cannot provide sufficient evidence, the distribution will be taxed as a dividend.

CA ANZ recommended that the statement include a discussion on the types of records that the Commissioner expects taxpayers and their advisers to provide to verify a distribution qualifies as ASC.