October 2, 2023 Neil Brydges Business Law, Taxation, Federal Taxes, Tax Disputes UPEs as loans - end of an era? October 2, 2023 Neil Brydges Business Law, Taxation, Federal Taxes, Tax Disputes If 16 December 2009 was the beginning of the Australian Taxation Office (ATO) treating an unpaid present entitlement (UPE) with a corporate beneficiary as a loan for purposes of Division 7A, could 28 September 2023 be the end of that era?