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Division 7A UPEs | Bendel decision challenges ATO’s views

10/10/2023

The decision in Bendel1 could have significant implications to Division 7A application, challenging the Commissioner’s long-standing position to treat unpaid present entitlements (UPEs) as loans. The Commissioner’s view is that where a company beneficiary of a trust has an UPE, this entitlement will generally be treated as a loan for Division 7A purposes, if it […]