From www.knowledgeshop.com.au: The ATO has issued draft determination TD 2024/D3 regarding Division 7A, indicating that a private company’s guarantee of a loan from another entity can trigger tax implications under section 109U.

Taxpayer alert TA 2024/2 identifies arrangements aimed at circumventing Division 7A by using guarantees, warning that private companies could be deemed to have provided unfranked dividends if not compliant.

The ATO is also increasing scrutiny on foreign residents disposing of Australian property, highlighting updates to the FRCGW regime effective from January 2025, including a rise in withholding rates and the removal of minimum property value thresholds.