Tax and commercial incentives no longer existed, said senior advocate at the institute Robyn Jacobson, as previous arrangements involving sub-trust interest-only loans were no longer available under TD2022/11 from 1 July.
“The interest-only aspect was the most attractive commercial feature of sub-trust arrangements,” Ms Jacobson said. “From a tax perspective, it may be that little benefit can be gained from implementing a sub-trust arrangement for unpaid present entitlements arising on or after 1 July 2022.”
