The Australian Taxation Office (ATO) recently announced the release of Taxation Determination (TD) 2025/6, Income tax: does section 109U of the Income Tax Assessment Act 1936 only apply to arrangements where a private company gives a guarantee to another private company? TD 2025/6, dated 24 September 2025, applies both before and after its date of issue, although it does not apply to taxpayers to the extent that it conflicts with the terms of settlement of a dispute agreed to before the dat…