Just before Christmas, the Tax Office released a very controversial draft ruling on the tax treatment of unpaid present entitlements (UPE). The draft ruling raises exceptionally complex trust and tax law issues which will have hard practical consequences for trustees, beneficiaries and their advisers. The draft ruling is intended to have both retrospective and prospective application depending on what technical issues are seen to be involved. This event identified the issues addressed by the draft ruling, considered the basis of the Tax Office's position and provided guidance on practical responses to this new approach.
maintenance