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Will a loan / payment to / between related companies (Pty Ltd) be treated as assessable income (unfranked dividend)?

  This situation is also known as inter - company loans / payments. Section 109K of Income Tax Assessment Act 1936 (ITAA 1936), states that a private company is not taken to pay a dividend because of a payment or loan to another company.

A situation like the above can frequently occur between two companies in a related group where there are numerous transactions between the two and share of resources.