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  2025 Division 7A

Has Division 7A changed forever post-Bendel?

Published Date: 6 Aug 2025

 

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This session unpacks Bendel and its implications, and examines:

  • The judgments in Bendel and implications for the tax treatment of UPEs to corporate beneficiaries (and an update on the Commissioner’s application for special leave to appeal to the High Court)
  • The practical implications of Bendel in managing clients’ UPE arrangements, including:
    • the ATO’s existing guidance and Interim Decision Impact Statement — what does the IDIS say and what doesn’t it say?
    • legacy UPE arrangements and sub-trust structures
    • new UPEs and future planning strategies.
  • Potential application of Subdivs. EA and EB, and sec. 100A—and ATO administration of the law using PCGs
  • The need to account correctly for UPEs and avoiding Div. 7A issues going forward
  • Key risk areas for practitioners, including ATO review periods, cross-referencing with sec. 109K, and tax agent exposure; and
  • Practical examples to illustrate compliant and non-compliant scenarios.
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Details

  • Published By: Michael Butler CTA
  • Published On:6 Aug 2025
  • Event Name:Barossa Convention
  • Session Name:Has Division 7A changed forever post-Bendel?
  • Read Time:30+ minutes
  • Took place at:Novatel Barossa Valley Resort

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