After Bendel: Division 7A, Anti-Avoidance, and Beyond

Join Sladen Legal's webinar on trust entitlements and new rulings. Learn more on WebinarCafe

Legal Webinar Benefits

Unpacking the Past, Present, and Future of UPEs 

The Full Federal Court’s decision in Commissioner of Taxation v Bendel (February 19, 2025) has redefined the tax landscape for trusts, ruling that unpaid present entitlements (UPEs) between a corporate beneficiary and a trust do not constitute a loan under s109D(3) of Division 7A. This outcome overturns years of ATO guidance and necessitates a reassessment of trust distributions and tax compliance obligations.

The ATO on 18 March 2025 lodging an application for special leave to appeal to the High Court, and the ATO’s interim decision impact statement on 19 March 2025 on the Full Federal Court decision, further add to the uncertainty of the coming months for advisors.

This session will give advisors an update on this changing landscape and what and the practical considerations for practitioners managing trust structures during the current lodgment season and beyond.

Register now for this webinar and stay informed on this evolving landscape.

Who should watch

Accountants, lawyers, and others interested in the impact of this High Court decision on trusts, and taxation .

Level of expertise

This webinar is for persons with some experience or interest in trusts and taxation and who are looking to improve their knowledge.

Presenters: Neil Brydges, Principal, Accredited Specialist in Tax Law; Philippa Briglia, Special Counsel.