Close
My Cart (0 items)

Login to TEN

Privacy Policy
Return
My Cart (0 items)
107648
Live Webinars

Live Webinar: Division 7A, Interposed Entities and the Middleman Trap

Division 7A remains a key focus for the ATO, and its broad drafting means some arrangements can unknowingly breach the rules. A critical area of concern is Subdivision E, which covers payments and loans made through interposed entities. This session breaks down how these provision

Date/Time

Thursday 6 November 2025
Vic, NSW, ACT, Tas: 11am to 12pm
Qld: 10am to 11am
SA: 10.30am to 11.30am

NT: 9.30am to 10.30am
WA: 8am to 9am

About the Webinar

Division 7A remains a key focus for the ATO, and its broad drafting means some arrangements can unknowingly breach the rules. A critical area of concern is Subdivision E, which covers payments and loans made through interposed entities. This session breaks down how these provisions operate, the risks they pose, and practical ways to manage compliance, including:

  • Division 7A application when interposed entity in receipt of payment/loan from private company makes payment/loan to another entity (secs. 109T & 109W ITAA 1936)
  • How the use of guarantees can impact on Division 7A applying (secs. 109U & 109UA ITAA 1936; TD 2024/D3; TA 2024/2)
  • Reconciling sec.109K (inter-company payments/loans not treated as dividends) with subdivision E (indicating they can be) (TD 2012/12)
  • Are complying loan terms required to avoid a deemed dividend occurring under Subdiv. E? (TD 2011/16; TD 2018/3)
  • How the distributable surplus rules apply when dealing with Subdiv. E
  • Who initiates a deemed dividend assessment under Subdiv. E (sec. 109V) and what are the amendment periods to be mindful of? 
  • Consequences of Subdiv. E applying
  • Practical examples

Presented By

Stephen Holmes
Partner, WMS Advisory Robina, QLD

Stephen Holmes, CTA, is a Partner at WMS Tax and Advisory based on the Gold Coast.

Stephen has worked in the profession since 1987 and held roles with National firms and a was managing principal at an ASX listed accounting firm before joining WMS in 2006.

Stephen holds a Master’s Degree in Economics from Macquarie University (1994), a Masters of Tax from the University of NSW (2000), a Juris Doctor degree from Bond University Law School (2013), and is currently studying a Masters of Laws at the University of Melbourne with a dedicated focus on specialised tax subjects.

Stephen is a regular speaker for various tax and accounting bodies throughout Australia. He has presented at national conventions and tax summits for the Tax Institute of Australia and has been senior tax and superannuation trainer with Chartered Accountants of Australia and New Zealand (CAANZ) for over 10 years.

In 2022, Stephen was named Tax Advisor (Accountant category) of the Year by the Tax Institute of Australia as a recognition of his involvement in the tax profession.

In practice, Stephen has a particular focus on capital gains tax, taxation implications of trusts, tax consolidation and corporate tax matters. He assists clients to legitimately reduce their overall tax burden by innovative structuring and detailed planning.

Stephen provides expert technical leadership at WMS Tax & Advisory, co-hosts a technical training program for accountants at the firm. A large and growing part of his practice is consulting to accounting professionals on tax matters.

 

Who Should Attend?

This webinar is suitable for accountants advising in taxation matters – Australia wide. This webinar is for practitioners with some knowledge in this area and looking to improve their knowledge.

CPD Certificate

Registered live webinar delegates will receive a CPD certificate for attendance at this webinar. Accountants can claim up to 1 CPD hour. This webinar has been designed to run for 1 hour, however, webinar lengths can vary depending on the level of questions and discussion.

While TEN takes all reasonable care to include accurate and up-to-date information regarding CPD category classifications and compliance obligations, information regarding CPD point allocation are provided as a guide only. Allocation of CPD points is subject to the CPD requirements of your jurisdiction, personal circumstances and professional requirements. You are solely responsible for determining whether a particular product is appropriate for your CPD requirements.

Enquiries/Assistance

If you need assistance or have an enquiry, please do not hesitate to contact our Webinar Coordinator, Jason Hooker on (03) 8601 7709 or email: [email protected]

Go to top