UPEs post the Bendel decision

2 Sep 2026 11:00AM – 12:30PM AEST

Division 7A

$195.00 +GST

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The Full Federal Court’s decision in February 2025 that a ‘loan’ for the purposes of s. 109 in Div 7A of the ITAA 1936 did not extend to unpaid present entitlements (UPEs) – i.e. it was not financial accommodation – generated widely varying responses:

the Commissioner was unmoved – the interim decision impact statement tells us that, pending the High Court’s decision, it is business as usual and anyway, the anti-avoidance provision in s. 100A of the ITAA 1936 could apply
some tax advisers were ready to object to any unfavourable decisions based on the Commissioner’s now impugned view which the ATO had issued to their clients
other tax advisers lamented the potential prospect of having to deal with UPEs under Subdiv EA

In this session we consider, subject to the outcome of the High Court appeal:

the Div 7A implications of a UPE being treated as financial accommodation i.e. a loan and the alternative if the UPE is treated as an equitable entitlement, but not a loan
the scope of Subdivision EA – UPEs
the Commissioner’s view of when the anti-avoidance provision in s .100A could be applied to a present entitlement: TR 2022/4 and PCG 2022/2
options for advisers in respect of their clients’ UPEs.

This webinar will be presented by one of TaxBanter’s experienced tax trainers.

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