16/06/2026
Steven Bendel vs. the Commissioner of Taxation ⚖️
After 17 years — through the AAT, the Full Federal Court, and finally the High Court — the answer is clear: unpaid present entitlements are not loans for Division 7A purposes.
In a 5–2 decision, the High Court's majority rejected the ATO's long-held position, confirming that a corporate beneficiary's mere failure to call for payment of a UPE does not constitute a loan under Division 7A.
📖 Learn more in our latest insight:
hallchadwickwa.com.au/our-insights/steven-bendel-vs.-the-commissioner-of-taxation
If you have any questions about how the Bendel decision could affect your affairs, please do not hesitate to reach out to your trusted Hall Chadwick advisor.
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