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Division 7A update: High Court confirms Bendel decision on UPEs

12/06/2026

The High Court has now handed down its decision in Commissioner of Taxation v Bendel, confirming the position for the taxpayer on Division 7A, unpaid present entitlements (UPEs), trust distributions, and private company loans. This is a landmark outcome for the taxpayer. The High Court has dismissed the Commissioner’s appeal, confirming that UPEs arising from […]

Full Federal Court denies deductions for transactions between related parties

03/03/2026

The Full Federal Court has ruled in favour of the Australian Taxation Office (ATO), disallowing deductions for transactions between related parties which were not documented adequately. In Commissioner of Taxation v S.N.A Group Pty Ltd [2026] FCAFC 10 a group of entities collectively referred to as the S.N.A Group carried on real estate businesses. The […]