Get In Touch
Tag: AAT
7
Apr
ATO’s appeal against decision that UPEs are not “loans” fails
The Full Federal Court recently dismissed the ATO’s appeal against an AAT decision that unpaid present entitlements (‘UPEs’) owing by a trust to a corporate beneficiary were not “loans” for Division 7A purposes. A corporate beneficiary had become entitled to a share of the income of a trust for the 2013 to 2017 income years. Parts of these entitlements remained