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 under Division 7A of the ITAA 1936.

The ATO has also updated its guidance on sales of land and small-scale subdivisions, providing examples that clarify the tax implications depending on the intent of the taxpayer regarding property transactions.

The examples differentiate between activities conducted for profit and those realized as a capital asset without commercial intent, impacting the tax treatment substantially.