From www.pitcher.com.au: In December 2024, the Australian Taxation Office published draft taxation determination TD 2024/D3, indicating that a deemed dividend could occur under Division 7A if a private company guarantees a bank loan to another private company in the group, which is then on-lent to a related trust or individual.

Pitcher Partners submitted a response to the draft, presenting their interpretation of the relevant provisions and advocating for safe harbours for taxpayers engaged in standard commercial financing arrangements.