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Division 7A and complex structures paper

Published on 19 Jul 13 by QUEENSLAND DIVISION, THE TAX INSTITUTE

Many SMEs have structures with interposed entities. Complying with TR 2010/3 and PSLA2010/4 continues to cause headaches and the spectre of Division 7A can lead to major problems? including:

  • complying with PSLA 2010/4 - can it lead to problems in the trust relationship?
  • dealing with UPEs in different structures involving interposed entities
  • restructuring issues - time to reconsider?
  • revisiting s109RB and asking for the Commissioner’s discretion for non-compliancewith PSLA 2010/4.

Author profile

Arthur Athanasiou CTA-Life
Photo of author, Arthur ATHANASIOU Arthur Athanasiou, CTA (Life), is an Accredited Tax Law Specialist and Principal of AGA Legal Pty Ltd. He is a highly competent and well-respected tax lawyer with 30 years’ experience. While he provides clients with tax and structuring advice, his main area of focus is in resolving tax disputes with the ATO and SRO and settling tax audits. Arthur also practises in matters involving tax agents and inquiries by the Tax Practitioners Board including appealing adverse TPB decisions. His practice also extends to white-collar crime, and other taxation offences. He also has a Deceased Estates practice. Arthur has qualified as a Chartered Accountant and is a former President of The Tax Institute. He has been appointed as an Adjunct Professor at La Trobe University Law School and chaired the Law Institute’s Tax Law Advisory Committee for a decade. Arthur has been recognized by Doyle's Guide who has recognized him as a "Leading Lawyer, Tax Law, Victoria" multiple times (2016, 2018-2024) and a "Recommended Lawyer, Tax Law, Victoria" (2015, 2017). Best Lawyers Peer Review recognised him as "Best Lawyer Trusts and Estates" (2022-2026) and for his work in Tax Law (since 2023). He is a widely published writer on taxation issues and regularly appears in mainstream media and presents at tax conferences and seminars. - Current at 03 June 2025
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This was presented at 2013 Queensland Annual State Convention .

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Individual sessions





Part IVA issues for SMEs

Author(s):  Graeme COOPER

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