Podcast
Unpacking Bendel and what it means for UPEs
The High Court has handed down its decision in Bendel. In this episode, we work through the majority’s decision.
Fletch Heinemann June 17, 2026
The High Court has handed down its decision in Bendel. In this episode, we work through the majority’s decision.
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.