AAT decision contradicts ATO position in relation to UPEs, Corporate beneficiaries & Div 7A
The recent AAT decision in the case of Bendel and Commissioner of Taxation [2023] AATA 3074 is in stark contrast to the ATOs longstanding position that an unpaid present entitlement of a corporate beneficiary constitutes the ‘provision of financial accommodation’ by the company to the distributing trust. […]
