ATO to treat new unpaid present entitlements as loans from 1 July 2022
The ATO has revised its view regarding unpaid present entitlements (“UPEs”) for Division 7A purposes that has been in effect since 16 December 2009. For UPEs arising on or after 1 July 2022, TR 2010/3 and PS LA 2010/4 will be withdrawn with the consequence that interest-only complying sub-trust arrangements will no longer be accepted.