(1) Each PDF has a venture capital sub - account in its franking account. The sub - account exists even if the PDF does not elect to become a participating PDF by keeping a record of it.
(2) To the extent that income tax is reasonably attributable to capital gains from venture capital investments, it generates a venture capital credit in the sub - account. There are other circumstances in which a venture capital credit arises.
(3) If a PDF receives a refund of that tax, a venture capital debit will arise for the PDF. There are other circumstances in which a venture capital debit will arise, such as on the payment of a distribution franked with a venture capital credit.