From www.knowledgeshop.com.au: The Full Federal Court dismissed the ATO’s appeal in the Bendel case, ruling that unpaid present entitlements (UPEs) owed to corporate beneficiaries are not considered loans for Division 7A purposes.

This decision distinguishes the obligation to pay from an obligation to repay, contradicting the ATO’s long-standing view since 2009.

The ATO has updated its guidance on the tax implications of selling land and small-scale subdivision projects, providing new examples to clarify income tax and GST consequences based on the taxpayer’s intent.