A franking credit black hole

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June 26, 2014 AUSTRALIA STRATEGY EU_140626 On Notes from the Field the one hand, the logic of the argument about the $5 billion on franking credits is that we should have higher company taxes so people might get more franking credits, it s illogical Joe Hockey, Australian Federal Government Treasurer A franking credit black hole In its current format, the Federal Government s proposed reduction in the corporate tax rate and introduction of the Paid Parental Leave Scheme on 1 July 2015 encourages stocks to lift payout ratios, issue special dividends or make more use of DRPs. Buy WES, CCL and ANZ for the surplus cash potentially on offer. Plans for a paid parental leave scheme The Federal Government s plans to fund its Paid Parental Leave (PPL) Scheme by imposing on large companies a 1.5% levy on taxable income. We estimate the revenue gained from the levy will significantly outweigh the Government s obligation under the scheme and prove net positive for the budget position. The legislation has hit a roadblock in the Senate, with no minor party or Labor willing to pass the legislation. Implications for investors As well as introducing the levy, the Government also plans to lower the corporate tax rate to 28.5%. In the transition to a lower tax rate, we estimate around 7% of the maximum franking credits payable must remain with the company and undistributed to investors. When the corporate tax rate was last cut (1 July 2001), franking balances were inflated to reflect the change in the corporate tax rate, but this hasn t yet been included in the policy announcement. We estimate that franking balances will increase by 0.7% of pre-tax profit per annum due mainly to the PPL. Furthermore, the effective marginal tax rate for both retail investors and institutions will be slightly greater than their marginal rate. High-yielding defensives under the microscope The loss of distributable franking credits increases an investor s marginal tax rate and encourages stocks to issue special dividends or lift year-end or interim dividends. CCL has the capacity to increase dividends by using cash. ANZ could lift its payout to return cash so it is more in line with the other banks. We also estimate that MTS could also have room to lift payout by end FY15. WES could also return cash, but we think this is less likely. Most of the stocks we analysed could easily increase gearing if they preferred. WOW, IAG, CBA, BOQ and MTS will have large franking credit balances relative to their franking. Other stock considerations BHP and RIO both have large franking credit balances due mainly to their dual-listed structure. Franking credit balances could be thought of as a 0% interest rate loan to the government by the company on the shareholder s behalf. These stocks could then be considered the Government s largest low-cost lender. As capex continues to wind down, these stocks could choose to issue special dividends. They have the balance sheet strength and the ability to lift payout ratios to fund special dividends. IMPORTANT DISCLOSURES, INCLUDING ANY REQUIRED RESEARCH CERTIFICATIONS, ARE PROVIDED AT THE END OF THIS REPORT. Designed by Eight, Powered by EFA

1. A CORPORATE TAX POLICY CHANGE The Federal Government proposed to upgrade the current PPL scheme in its May Budget. Its proposed scheme would pay mothers up to A$50,000 for six months maternity leave and would begin on 1 July 2015. The Budget papers estimate the scheme will cost A$2.0bn per annum over the next four years. We made our own rough estimate of the cost of the scheme by using data on the number of births, average weekly earnings and female labour force participation. In our calculation, we assume an 1%pa increase in the number of births and a 3%pa increase in average weekly earnings. We also assumed 50% of births are to mothers in the workforce. However, it s possible that this percentage is lower given the 2011 census showed that around 60% of couple families had more than one child. This suggests a reasonably large skew of births by stay-at-home mothers. If we make this assumption, then we agree with the Government that the cost of the scheme would be around A$2.0bn pa. Figure 1: Estimated cost of paid maternity leave scheme Female average weekly earnings Period Births pa ($/week) Average salary (A$ pa) Estimated cost of scheme (A$bn) End 2013 308,000 854 44,417 FY14 est 309,540 867 45,083 FY15 est 312,635 893 46,436 2.0 SOURCES: CIMB, ABS. We assume 1% growth in births (the average in the past 20 years), a 3% increase in wages. We also assume that 50% of new born children have mothers in the workforce (the female participation rate) and 60% of newborn children are born to stay-at-home mothers. In FY16, the Federal Government plans to lower the corporate tax rate from 30% to 28.5% and introduce the PPL scheme. The PPL scheme will be funded by companies earning more than A$5mpa in taxable income. These companies will pay a 1.5% levy on their taxable income. The policy has the impact of introducing a threshold to the corporate tax structure, with the tax burden skewed more toward companies with taxable income in excess of A$5m (Figure 2). Figure 2: Impact of the changes on profit after tax Pre-tax profit Income Tax (28.5%) Paid parental leave levy (1.5%) Effective tax rate (%) 5,000,000 1,425,000 Nil 28.5 10,000,000 2,850,000 75,000 29.3 100,000,000 28,500,000 1,425,000 29.9 SOURCES: CIMB, FY15 Federal Government Budget We estimate the revenue raised by the levy, by using FY12 data from the Australian Tax Office (ATO). Even with some conservative forecasts for taxable income growth (5%) over the next three financial years, the Federal Government s tax revenue (A$9bn) seems likely to be much greater than its liability for funding the scheme (Figure 3). Figure 3: Estimated revenue raised by PPL levy FY12 Taxable income (A$bn) >A$5m (A$bn) A$5m (A$bn) Est levy revenue (A$bn) Mirco business (0-A$2m) 25 Small (A$2-A$10m) 23 12 Medium & Large business ( > A$10m) 191 191 Total 240 203 633 9 SOURCES: CIMB, Australian Tax Office. We assume 50% of small business taxable income is from companies with more than A$5m in taxable income. We increase taxable income by 5% in both FY14, FY15 and FY16 2

1.1 Implications for Dividend Imputation The levy is not treated as income tax, so it won t attract a franking credit. We show the effect of the changes to tax and the introduction of the Paid Parental Leave Scheme, by calculating the tax burden of a company earning A$100m in pre-tax profits. We assume the payout ratio remains constant and 100% (Figure 4). The Government is also raising the top marginal tax rate on personal income by 2ppt in FY15 to 49%, so we include this in our calculation of the effective tax rate of retail investors. However, the increase in the personal top marginal tax rate means retail investors receive A$2m less after tax in grossed-up dividends. Institutional investors are unaffected (Row 10 Figure 4). In FY16, the corporate tax rate is cut to 28.5% and the 1.5% levy is introduced in accordance with the proposed legislation. A$0.6m in franking credits generated during the year must remain with the company and cannot be paid to investors. In each year the franking balance will increase by this amount, all else being equal. The maximum franking credit that can be paid to investors for that financial year is then A$27.9m, which gives a grossed-up dividend of A$98m. The A$2.1m (7%) of the franking credits from profits earned prior to 1 July 2015 will remain with the company and can t be distributed. This forces retail investors to pay an effective tax rate on their dividends (50%) greater than the top marginal rate (49%). Institutional investors will pay an effective tax rate greater than the tax rate on distributions (15%). The maximum franking credit payable is calculated using the following formula: Max franking payable = dist* corp tax rate/ (100% - corp tax rate) It s important to recognise that the franking paid in the distribution comes from the company s current franking credit balance. Once the franking balance is distributed to shareholders, the tax paid generates a franking credit that adds to the balance. Figure 4: Impact of changes to corporate tax, income tax and the paid parental leave levy FY14 (A$m) FY15 (A$m) FY16 (A$m) PPL levy (A$m) Pre-tax profits (1) 100 100 100 Company tax (2) 30 30 28.5 1.4 After-tax profits (3)= (1)- (2) - levy 70 70 70.1 Franking credits (4)=(2) 30 30 28.5 Dividend (5)= (3) 70 70 70.1 Maximum franking credit payable (6)= (3)*(2)/(100-(2)) 30 30 27.9 Grossed up dividend (7)=(5)+(6) 100 100 98.0 Franking credits remaining with company (8)=(6)-(4) 0 0 0.6 Shareholder after-tax income Individual Fund Individual Fund Individual Fund After-tax cash distribution (9)=(7)*(100-marginal rate)/100 (A$m) 53.0 85.0 51.0 85.0 50.0 83.3 Effective tax rate on pre-tax profits (10)=((1)-(9))/(1)*100 (%) 47 15 49 15 50.0 16.7 SOURCES: CIMB There has been no announcement by the Government on any transitional measures. However, in a note to its clients, Deloitte suggested the corporate tax rate used in the formula to calculate the maximum franking credit should remain at 30% until the franking credits generated on profits prior to 1 July 2015 are fully distributed (Company Tax Rate Reduction and Parental Leave Levy: Impact on Dividends, June 2014). 3

Another option would be to inflate the franking balance generated under the higher corporate tax rate and pay out franking at that higher rate. This was the approach taken when the corporate tax rate was last lowered from 34% to 30% on 1 July 2001. Back then franking balances were inflated by the difference in the corporate tax rate. Adj bal = bal * (t rate (t-1) /(100-t rate (t-1) )*(100-t rate (t) )/ t rate (t) Companies affected by the change in tax policy may consider the following to protect shareholder interests: Increasing franking where the franked amount is less than 100%, particularly where the franking balance is relatively large. Running down their franking credit balance if it s already large relative to the franking credit paid out. Using cash to increase the grossed up dividend. Increasing their payout ratio. Using debt to pay dividends. 1.2 Politics a key consideration The budget remains gridlocked in the Senate, with the Greens deciding recently to reverse their support for the return of fuel excise indexation. The introduction of the Temporary Budget Repair Levy is currently the only major policy initiative from the budget to pass the Senate. Importantly, the PPL scheme only has the support of three senators, and if this remains it s unlikely to become legislation. This would also threaten the proposed cut to the corporate tax rate and eliminate need for the PPL Levy. At this stage, the bills most likely to pass the Senate are the deregulation of university fees and the abolishment of the carbon tax. Figure 5: Bill support in senate from 1 July 2014 Party Seats Deficit reduction tax Paid parental GP Fuel excise Increase in Deregulation of Abolish carbon leave scheme co-payment indexation pension age University fee s and mining tax Coalition 33 yes yes yes yes yes yes yes Australian labor party 25 yes no no no no no no Greens 10 no no no no no no no Palmer united party 3 no no no no no undecided yes Nick Xenophon 1 na no no no no possible Democratic labour party 1 na no Need to amend no yes Liberal democratic party 1 no no yes no yes yes Family first 1 no no undecided no yes yes Australian motoring enthusiast party 1 na undecided undecided no undecided undecided 76 56 (already passed) 33 34-36 33 33-36 35-39 40-41 SOURCES: Australian Electoral Commission Note: following the senate re-election in Western Australia 4

2. IMPACT ON HIGH-YIELD SECTORS Investors are attracted to high-yielding sectors because of the large dividend they pay. Consequently, any change to tax policy could change company dividend policy and risk altering investors perception of these stocks. We have used our analysts estimates of dividends and tax payable to estimate the franking credit balances at the end of each of the next three years using the current tax arrangements. This allow us to analyse the impact of the proposed changes to policy. Only AMP and TCL don t pay a 100% fully franked dividend (Figure 6). We estimate AMP, SUN and WES will see a substantial decline in their franking credit balances by FY16. Indeed, by then they will have each paid away more than 70% of the franking balance. We expect CCL s franking balance to increase by 50%, but we expect that by FY16 77% of this will be paid out. The large decline we expect in SUN s franking credit balance is mainly due to expectations of our analyst Richard Coles that the company will issue a fully franked special dividend in FY14. Our Banks analysts, John Buonaccorsi and Ashley Dalziell, expect all major banks and BOQ to increase in their franking paid to around 40% of their franking balance by FY16. AMP, CCL, and WES are expected to maintain their franking paid at low levels relative to the size of their balances. Figure 6 High-yielding stocks - Estimates of Franking Balances (FY14-16) under current tax arrangements (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) FY13 Frank'g Frank'g Balance (%) ($Am) FY14 FY14 Frank'g Div Contribution ($Am) ($Am) FY14 FY14 Frank'g Franking Balance paid ($Am) ($Am) FY15 FY15 Frank'g Div Contribution ($Am) ($Am) FY15 FY15 Frank'g Franking Balance paid ($Am) ($Am) FY16 FY16 Frank'g Div Contribution ($Am) ($Am) FY16 FY16 Frank'g FY16 Frank'g Franking paid ($Am) Balance ($Am) Paid % Balance AMP 60 196 741 210 191 215 812 151 209 158 887 123 228 53 81 ANZ 100 1,335 5,240 2,714 2,246 1,803 5,541 2,881 2,375 2,309 5,946 3,086 2,548 2,847 47 BOQ 100 106 242 133 104 136 294 161 126 171 318 173 136 208 40 CBA 100 3,421 6,669 3,323 2,858 3,886 6,900 3,417 2,957 4,346 7,288 3,616 3,124 4,839 39 CCL 100 42 381 192 163 71 442 175 189 56 473 208 203 62 77 IAG 100 756 762 463 327 892 797 407 341 957 845 418 362 1,013 26 MTS 100 102 163 71 70 102 99 89 42 149 118 85 50 183 22 NAB 100 2,023 4,894 2,499 2,097 2,424 5,206 2,621 2,231 2,814 5,612 2,820 2,405 3,229 43 SUN 100 551 1,289 172 552 171 1,058 372 453 89 1,135 395 486 (2) 100 TCL 23 307 591 3 58 249 742 7 80 176 805 7-183 0 TLS 100 283 3,609 1,735 1,547 471 3,733 1,781 1,600 652 3,857 1,895 1,653 894 65 WBC 100 1,891 6,214 3,328 2,663 2,556 6,354 3,371 2,723 3,204 6,766 3,551 2,900 3,855 43 WES 100 243 2,394 1,030 1,026 247 2,740 1,088 1,174 160 3,046 1,269 1,305 124 91 WOW 100 1,943 1,744 954 747 2,149 1,894 1,007 812 2,345 2,045 1,065 876 2,533 26 SOURCES: CIMB ANALYST ESTIMATES, COMPANY REPORTS FY14 Franking Balance: (6) = (2) + (4) (5) Maximum franking paid FY14 (5) = (3) x 30% / (100%-30%) x (1) / 100. Assumes a corporate tax rate of 30% FY16 franking paid as a percentage of the franking balance (15) = (12)/(10)*100 We now analyse the impact of the change in tax policy on the high-yielding stocks by calculating the difference between the maximum franking credits payable assuming the new tax arrangements and that we expect them to pay under the current tax arrangements. Of course, during the transition to a lower corporate tax rate the concern is that franking credits become withheld in the franking credit balance. Our estimates of the amount of franking withheld are in column 7 (Figure 7). In most cases, the franking balances increase after the lower corporate tax rate is applied to pre-tax profits. The introduction of the PPL levy means around 0.6% of pre-tax profit must be retained by the company annually. 5

Figure 7: FY16 Franking Balances - Reduced Corporate Tax Rate (28.5%) Franking (%) (1) (2) (3) (4) (5) (6) (7) (8) (9) FY15 Franking Balance ($Am) FY16 Dividend ($Am) FY16 Franking Contribution ($Am) Contribution Differe nce from 30% rate FY16 Franking paid ($Am) Frank paid Diff from 30% Tax Rate ($Am ) FY16 Franking Balance ($Am) Difference from 30% tax rate AMP 60 158 887 106 (17) 212 (16) 51 (2) ANZ 100 2,309 5,946 2,918 (168) 2,370 (178) 2,857 10 BOQ 100 171 318 165 (9) 127 (10) 209 1 CBA 100 4,346 7,288 3,422 (194) 2,905 (218) 4,863 25 CCL 100 56 473 197 (11) 188 (14) 64 3 IAG 100 957 845 395 (22) 337 (25) 1,016 3 MTS 100 149 118 80 (5) 47 (4) 182 (2) NAB 100 2,814 5,612 2,666 (154) 2,237 (168) 3,243 14 SUN 100 89 1,135 368 (27) 452 (34) 5 7 TCL 0 176 805 4 (3) - - 180 (3) TLS 100 652 3,857 1,800 (95) 1,538 (116) 915 21 WBC 100 3,204 6,766 3,373 (178) 2,697 (203) 3,880 25 WES 100 160 3,046 1,206 (63) 1,214 (91) 152 29 WOW 100 2,345 2,045 1,005 (60) 815 (61) 2,534 1 SOURCE: CIMB ANALYST ESTIMATES, COMPANY REPORTS FY16 final franking Balance: (8) = (2) + (4) (6) Maximum franking paid (4): (3) x 28.5% / (100%-28.5%) * (1) / 100. Assumes a corporate tax rate of 28.5% Column 4 is the franking contribution of the component of tax paid adding to the franking balance 3. CAPITAL MANAGEMENT OPTIONS Franking credit balances can be thought of as an interest-free loans made by the company on behalf of its shareholders to the Government. Indeed, it would seem to be good financial management practice to keep these balances as low as possible. In this section of the note, we look at the different options companies have to increase dividends. We also include BHP and RIO in this analysis because of their large franking balances relative to other stocks. BHP (A$11.3bn) and RIO (A$14.3bn) have built up large franking credit balances mainly because of their dual-listed structure. The dividend paid to Australian investors is fully franked. However, a large component of the dividend paid from Australian taxable earnings is paid to offshore investors in the Australia-listed entity and the listed entity in the UK. This means a large proportion of the tax paid on Australian profits can t be distributed to local shareholders as imputation credits. As these companies continue to wind down their capex there should be more cash generated and an incentive to lift the payout. This could occur even if the benefit for offshore investors would disproportionally less than domestic investors. Conversely, a buyback would be another way to proportionally return capital to shareholders. 3.1 Cash In FY16 we expect CCL, BHP, RIO and WES will have a relatively large amount of cash on their balance sheets. Figure 8: Cash % of Total Assets (ex-financials) 2016F (%) 2015F (%) 2014F (%) 2013A (%) Avg (2009-2012) BHP 11.8 9.1 7.0 4.1 10.3 CCL 22.6 26.1 24.7 21.6 12.8 MTS 0.7 0.7 0.6 1.2 3.9 RIO 10.7 9.0 7.0 9.2 6.8 TLS 5.0 6.0 9.0 6.4 6.3 WES 7.4 8.1 8.8 3.1 3.6 WOW 4.4 3.8 4.0 3.8 4.8 SOURCES: CIMB ANALYST ESTIMATES, COMPANY REPORTS 6

The major banks must retain cash on their balance sheets to meet Basel III regulations. Our banks team believes additional cash can only be distributed to shareholders once their Common Equity Tier 1 Capital Ratio exceeds 9%. By FY16, they expect all major banks to have this ratio greater than 9%, putting them in a position of surplus cash. Figure 9: Basel III Common Equity Tier-1 2016F (%) 2015F (%) 2014F (%) 2013A (%) 2012A (%) ANZ 9.3 8.9 8.5 8.5 8.8 CBA 9.3 9.3 8.7 8.2 7.8 NAB 9.2 9.0 8.6 8.4 8.3 WBC 9.4 9.1 9.1 9.0 9.1 SOURCES: CIMB, COMPANY REPORTS The capacity of the high-yielding insurers such as AMP, SUN and IAG to use cash to pay special dividends also has to be considered within their regulatory environment. Our insurance analyst, Richard Coles, assesses the excess capital position for the insurers by examining their capital position against their PCA (prescribed capital amount), which is set by the Australian Prudential Regulatory Authority (APRA). In the case of SUN, its NOHC holding structure is similar to Macquarie, so we calculate excess capital at the group level. 3.2 Payout Another way to pay a special dividend is to deliver it from earnings. Our Banks team expects ANZ retain its payout ratio at around 71%, which is lower than the other Banks and that may give it room to increase dividends. MTS is expected to have to have a payout ratio of only 61% by FY16 and places it in a good position to increase dividends. We estimate that BHP and RIO will have relatively lower payout ratios than the other stocks, but higher than their post-financial crisis average. Our analyst, Michael Evans, expects RIO s payout ratio to continue to increase, but he expects BHP s ratio to decline slightly during the next couple of years. SUN already has a high payout ratio and our analyst expects it to decline after the special dividend is paid in FY14. WES has an already relatively high payout ratio, and we expect it to be 100% in FY14 and FY15. CCL s payout is relatively high (88%) and is expected to remain at this level during the next couple of years. Figure 10: Payout Ratios 2016F (%) 2015F (%) 2014F (%) 2013A (%) Avg (2009-2012) AMP 76.2 76.2 72.0 81.0 82.1 ANZ 71.2 71.0 71.0 70.7 71.5 BHP 47.8 45.3 46.7 51.0 33.3 BOQ 75.5 74.9 75.0 76.6 48.5 CBA 77.3 77.3 76.8 77.8 77.0 CCL 88.4 87.7 87.6 88.4 75.0 IAG 84.1 81.7 68.5 70.4 88.6 MTS 61.0 63.3 69.9 92.0 83.9 NAB 76.2 76.1 76.2 75.8 74.0 RIO 36.8 37.7 38.8 34.7 19.1 SUN 77.7 77.4 100.0 100.0 76.4 TLS 88.6 91.2 90.5 91.4 93.8 WBC 80.9 80.0 79.5 78.4 75.2 WES 100.0 100.0 100.0 92.1 91.3 WOW 72.4 72.4 71.3 72.0 70.2 SOURCES: CIMB, COMPANY REPORTS 7

3.3 Gearing Some companies that have low gearing could increase this to pay a special dividend. We expect WES and BHP both have moderate levels of gearing by FY16. However, our analyst Daniel Broeren expects WES will be more likely to use its balance sheet strength for acquisitions rather than delivering cash to shareholders. CCL issued two special dividends last year and has only modest gearing. Our TLS analyst, Ian Martin, expects TLS to slightly decrease its modest level of gearing at least until FY16. Our resources analyst, Michael Evans, expects BHP to steadily lower gearing back to its long-run average. Figure 11: Gearing ratio (ex-financials) 2016F (%) 2015F (%) 2014F (%) 2013A (%) Avg (2009-2012) BHP 23.9 25.6 28.4 28.5 23.7 CCL 45.6 47.0 50.7 59.4 54.2 MTS 30.7 33.7 34.2 31.7 37.7 RIO 25.6 28.1 31.2 34.9 28.6 TLS 49.9 50.9 51.7 53.2 51.2 WES 17.4 17.2 16.9 18.0 16.0 WOW 35.1 37.6 39.7 32.2 30.9 SOURCES: CIMB, COMPANY REPORTS Gearing Ratio measured as Debt/(Debt+Equity In summary, our analysis of gearing suggests most companies we analysed have the capacity to lift gearing to fund a special dividend. BHP and WES are probably best-placed to do this even though we suspect these companies will be less likely to increase gearing to raise dividends. 8

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Distribution of stock ratings and investment banking clients for quarter ended on 31 March 2014 1416 companies under coverage for quarter ended on 31 March 2014 Rating Distribution (%) Investment Banking clients (%) Outperform/Buy/Trading Buy/Add 56.2% 4.6% Neutral/Hold 28.0% 2.7% Underperform/Sell/Trading Sell/Reduce 15.8% 1.0% As at the time of publishing this report CIMB is phasing in an absolute recommendation structure for stocks (Framework #1). Please refer to all frameworks for a definition of any recommendations stated in this report. CIMB Recommendation Framework #1 Stock Ratings Definition Add The stock s total return is expected to exceed 10% over the next 12 months. Hold The stock s total return is expected to be between 0% and positive 10% over the next 12 months. Reduce The stock s total return is expected to fall below 0% or more over the next 12 months. 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An Underweight rating means investors should be positioned with a below-market weight in this country relative to benchmark. CIMB Stock Recommendation Framework #2 * Outperform The stock's total return is expected to exceed a relevant benchmark's total return by 5% or more over the next 12 months. Neutral The stock's total return is expected to be within +/-5% of a relevant benchmark's total return. Underperform The stock's total return is expected to be below a relevant benchmark's total return by 5% or more over the next 12 months. Trading Buy The stock's total return is expected to exceed a relevant benchmark's total return by 3% or more over the next 3 months. 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