Robert Gottliebsen has again used his column on these pages to opine about Labors dividend imputation reforms.

Now, lest I be misunderstood, let me be clear at the outset.

I respect Mr Gottliebsen as a longstanding journalist and my disagreement with his arguments shouldnt be seen by him or anyone else as personal attack on him. He is entitled to his views, but I am entitled to rebut them.

And I say, respectfully, his arguments are confused and somewhat shrill.

This time he has focused less on the economics of the issue and more on the politics.

He argues that, if the election was delayed until November, the Liberals would be able to successfully campaign on this issue. Well, I appreciate his concern but lets be clear: if Labor had only just announced this policy he may have a point.

The policy was announced almost a year ago: last March. Just before the Batman by-election. Labor won the by-election with a swing to us. We then won the Longman, Perth and Braddon by-elections with swings to us.

The Liberals ran hard on the imputation issue on the retiree-heavy Bribie Island. They were rewarded with a 10 per cent swing against them. They campaigned on the issue in the Wentworth and Mayo by-elections. They lost.

Now let me be clear, the Labor Party has not one inch of complacency about the upcoming election.

But nor do we fear a Liberal scare campaign.

Because across Australia people, including many who will not be able to access refundable credits under Labors policy, both respect a political party that has the courage to put its policies out long before an election and also know that some of the tax concessions that favour higher wealth individuals simply cant go on.

In 2014-15, $5.9 billion was spent on refunding dividend imputation credits. The commonwealth government in the same year spent less than this on public schools ($5.2 billion).

This cant go on.

Every time Mr Gottliebsen, Josh Frydenberg or anyone else draws attention to Labors plans, they increase the moral authority of our mandate, if we receive one, to pass this reform through the parliament.

Now, Mr Gottliebsen then praises the original Paul Keating dividend imputation reforms which operated between 1987 and 2000. He calls it brilliant policy. I agree.

Thats why I want to return dividend imputation to the original Keating model.

Every criticism that is made of our policy would have to apply to the operation of the original Keating model.

Mr Gottliebsen reckons our plan discriminates in favour of industry funds and has previously used emotive language about union mates.

Well, put aside the fact industry funds are jointly managed by unions and employers. The fact is industry funds are treated the same way as retail and bank funds. And all these funds pay tax.

Allowing them to use franking to offset that tax is a fundamental principle of avoiding double taxation.

In fact, it is tax refunds to non-tax-paying SMSFs and individuals which is the anomaly in our tax system: no other element of our personal income tax system involves refundable credits. None.

Finally Mr Gottliebsen has accused me of telling Australians to invest overseas.

Mr Gottliebsen is entitled to his argument but he is not allowed to assert I have said things that I have not. I have not encouraged or recommended investors to do anything.

What I have done is point out that if people are making investment decisions solely on the basis of franking credits, the tax system is then distorting investment when we are meant to ideally have a non-distortionary tax system.

And, just yesterday, The Australian published comments from the University of Melbournes Professor Kevin Davis, formerly the chief economist of the governments Financial Systems Inquiry, who commented on dividend imputation: It wasnt meant to lead to zero taxation of corporate income which occurs when dividends are paid to investors on zero marginal tax rates and rebates paid.

That has created a significant economic distortion and, while removing the rebate may be painful for those who have structured their investments to maximise gains from this tax arbitrage, such a change is warranted.

And just remember, 92 per cent of individual taxpayers are unaffected by Labors reforms to refundability and dividend imputation.

Let me finish by inviting your readers to imagine a world, for the sake of the argument, in which every shareholder is a retired non-taxpayer.

In this world, the tax office would collect tax at the prevailing corporate rate from business and then we would refund every single dollar to the company owners: the shareholders. The corporate tax rate would effectively be zero.

Some people might think thats a good thing. I dont.

And well be asking the Australian people at the election to agree with us.

This opinion piece was first published in The Australian on Friday, 25 January 2019.