ATO Finalizes Guidance on Use of Guarantees to Circumvent Division 7A

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 taxpayer…
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