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When is a loan a loan? Tax aspects presentation

Published on 20 Sep 07 by VICTORIAN DIVISION, THE TAX INSTITUTE

This presentation covers:

  • recent Division 7A changes
  • issue in forgiving loans
  • strategies for solving Division 7A problems as set out in PS LA 2007/20
  • debt equity rules, SME carve-outs
  • loans as traditional securities - tax issues.

Author profile

Chris Wookey CTA-Life
Photo of author, Chris WOOKEY Chris Wookey, CTA (Life) operates his own specialist tax consulting practice after previously having been a principal in the tax consulting division of Deloitte Private in Melbourne. A finalist in The Tax Institute’s Tax Adviser of the Year Awards for 2020 and 2022 and made a life member of The Tax Institute in September 2023, he has over 30 years’ experience in the chartered accounting profession and is a member of The Tax Institute’s national SME Technical Committee and had been its representative on the ATO’s Private Groups Stewardship Group from 2021 to 2022. Chris was also a member of the Board of Taxation’s Reference Group for its Review of Small Business Tax Concessions. His experience, centred on issues encountered by private groups, includes providing input to Treasury in relation to the proposed targeted amendments to the Div 7A integrity rules and participating in confidential consultations with the ATO in relation to the 2022 and 2023 developments in relation to section 100A. - Current at 29 January 2026
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This was presented at When is a Loan a Loan? .

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Individual sessions

Some legal aspects of loans

Author(s):  Michael Bearman

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