There is the possibility that overpayments of provisional tax resulting from shareholder salary accruals could be transferred to shareholders as tax credits rather than tax payments.
One of the other proposals to improve provisional tax, set out in the Better Business Tax issues paper, is for a company to pay tax on behalf of its shareholder-employees when they are paid salaries. The tax paid becomes a tax credit which the shareholder-employee can use against their tax liability. The purpose of this proposal is to remove shareholder-employees from provisional tax obligations altogether.
Whilst these two proposals sit separately at the moment, there is the possibility of reviewing whether they could be integrated.