This paper covers:
- Interprets the circumstances when a company will provide 'financial accommodation' to a trust
- Affects company sub-trust arrangements, including those that were previously endorsed by the Commissioner in Taxation Ruling 2010/3 and Practice Statement PSLA 2010/4
- Changes the Division 7A treatment of UPEs owing to companies
- Might interact with the 'targeted amendments to Division 7A' which were originally announced by the Government in the 2016-17 Budget.