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Tax litigation - HLS Tax Law Brisbane
Division 7A

The Bendel decision: ATO’s UPE loan view is overturned

The Full Court in Commissioner of Taxation v Bendel [2025] FCAFC 15 has overturned the ATO’s longstanding view that unpaid present entitlements (UPEs) to private companies are loans under Division 7A.

Sarah Lancaster March 3, 2025

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