From www.pitcher.com.au: The ATO’s new guidance states that private companies providing guarantees or security for third-party loans can trigger deemed dividends under Division 7A if the loan benefits shareholders.
This applies when a guaranteed loan is then on-lent to a trust or individual, raising potential compliance issues for taxpayers.
The ATO intends to focus on arrangements designed to circumvent Division 7A, putting taxpayers on notice about their compliance obligations.