Taxation Issues on Release of a Company’s Unpaid Present Entitlement
Taxation Determination TD 2015/20, released by the ATO on 25 November 2015, explains the Commissioner’s view on whether a release by a private company of its unpaid present entitlement (UPE) constitutes a “payment” under the Div 7A shareholder loan rules, contained in Pt III of the Income Tax Assessment Act 1936 (ITAA 1936). The TD […]