In Traynor & Ors v Federal Commissioner of Taxation [2026] ARTA 2024, the Administrative Review Tribunal has confirmed that amounts recorded in financial statements as loans, which do not have corresponding formalised loan agreements, will be treated as dividends for the purpose of Division 7A of the Income Tax Assessment Act 1936 (Cth). Businesses that operate as a corporate group must be aware and consider the risk of intercompany transfers being characterised as a Div 7A loan.