- Loans in existence on 4 December 1997
- Unpaid present entitlements (UPE) including UPEs that are held on sub-trust and those in existence before 16 December 2009
- The ongoing relevance of a company having a distributable surplus
- The maintenance of existing Division 7A arrangements with particular reference to the cash flow considerations
- Unwinding existing Division 7A arrangements
- Primary production companies with substantial retained earnings being a source of finance to associated individuals and related entities for commercial and other purposes
- The interaction with other taxation provisions.