
Division 7A Bendel Decision: High Court Clarifies UPEs for Trusts and Corporate Beneficiaries
On 10 June 2026, the High Court of Australia dismissed the Commissioner’s appeal in Commissioner of Taxation v Bendel [2026] HCA 18 (the Division 7A Bendel decision). The appeal concerned whether an unpaid present entitlement (UPE) owed by a trust to a corporate beneficiary could be treated as a “loan”



