Blog categorized as Division 7A

Division 7A Deep Dive

If you thought Division 7A compliance was all about keeping loan agreements tidy and tracking interest rates — think again.

The ATO’s latest Taxation Determination TD 2025/5 has turned the spotlight on an issue that’s long been quietly debated: what really counts as a “repayment”?


Spoiler: not all rep...


Division 7A in 2025

Division 7A has always been the quiet disruptor of private-group tax planning. It doesn’t roar like transfer-pricing or DPT, but every few years it surfaces with something that keeps advisers awake at night.


This year it’s a mix of familiar and fresh: a small drop in the benchmark rate, a new determi...
Division 7A and the Bendel Blow 

We’ve been keeping an eye on the Division 7A debate for years, and April’s tax update served a firm reminder that this is far from settled. The Full Federal Court has now unanimously ruled against the ATO in Commissioner of Taxation v Bendel, concluding that an unpaid present entitlement (UPE) to a ...

Division 7A, Notional Loans and the ATO’s Latest Draft

Let’s be honest — Division 7A has never been light reading. And just when we start to feel comfortable navigating the usual repayment options, TD 2025/D2 lands in our inbox, reminding us that the waters run deeper than we thought.


This new draft determination focuses on section 109R — the anti-avoida...