Under Section 109NA of the Income Tax Assessment Act 1936 (ITAA 1936) a private company is not taken to pay a dividend because of a distribution  (payment) or loan made in the course of the winding up of a company by a liquidator.

Please note that if the loan is not repaid by the end of the following income year, the company will have taken to paid a dividend under subsection 109D (IA) ITAA 1936.