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Division 7A: Hotspots with common structures and strategies paper


With the ATO blowtorch squarely aimed at Div 7A, this paper turns the heat up on Div 7A issues arising from common structures and strategies post
16 December 2009, together with possible ways of dealing with them.

Issues to be examined include:

  • multi-layered entities, creating multiple Div 7A problems 
  • loans and payments through interposed entities
  • strategies to deal with UPEs, including transferring receivables
  • UPEs becoming loans because of the trust deed
  • non-resident companies and/or shareholders
  • the use of property – when and how to value it?
  • the use of guarantees, security and subrogating rights to UPEs.

Author profile:

Author Photo - Paul HOCKRIDGE
Paul Hockridge FTIA is a Tax Partner at Deloitte with over 30 years experience in Tax, asset protection, estates-succession planning, FBT and salary packaging. Paul specialises in advising high wealth families and closely held businesses and advises mainly accounting and law firms. Paul is a member of various professional association committees and has been involved in consultation with both Federal and State Governments on a variety of tax matters.
Current at 17 October 2008
Click here to expand/collapse more articles by Paul HOCKRIDGE.


This was presented at 51st Victorian State Convention .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Resolving tax disputes

Author(s):  Michael BEARMAN

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Transfer pricing: The ATO perspective

Author(s):  Michael JENKINS

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Family trusts and the family court

Author(s):  Geoffrey DICKSON

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The new Part IVA - Clarification or extension?

Author(s):  Simon STEWARD

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Cases review

Author(s):  Jerome TSE

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The new transfer pricing rule

Author(s):  Michael SELTH

Materials from this session:

Reportable tax positions

Author(s):  Judy MORRIS

Materials from this session:

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