From www.pitcher.com.au: The ATO has formalised its stance on repayments of Division 7A loans, indicating that repayments may be disregarded if new loans are obtained indirectly through other entities, potentially leading to deemed unfranked dividends.

This is outlined in Draft Taxation Determination TD2025/D2, which extends the application of existing anti-avoidance provisions to include repayment scenarios involving multiple interposed entities.

Taxpayers are advised to carefully review their loan arrangements, as disregarded repayments can lead to significant tax implications if the provisions are triggered.