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  2026 Division 7A

Division 7A in Practice – Challenges and Opportunities

Source: Victoria

Published Date: 23 Jul 2026

 

This panel explored the practical challenges of Division 7A, focusing on shareholder loans, UPEs, and the real‑world issues that arise in restructures and trust distributions. Panellists discussed some mini-case studies to focus on thorny Div 7A issues, the ATO’s current approach, common compliance traps, and practical strategies for managing risk while maintaining commercial flexibility. Practical issues include UPE’s and minors, setting off loans, forgiveness and statute barred debts, s109C and the lease of company property and whether Div 7A loans are preferable to franked dividends, corporate and natural person beneficiaries and estate planning.

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