TD 2022/11 – Division 7A and UPEs – is this the final word?
On 13.7.22, the ATO issued Taxation Determination TD 2022/11 (TD), settling its final position on UPEs Income tax: Division 7A: when will an unpaid present entitlement or amount held on sub-trust become the provision of ‘financial accommodation’? This is Division 7A of Part III of the Income Tax Assessment Act 1936 (ITAA 1936) and UPEs are…