The above case may lead the way for taxpayer to be able to use corporate beneficiaries with more flexibility.  

Basically, distributions from a discretionary trust to a corporate beneficiary can remain as an UPE (Unpaid present entitlement).  This means the funds can remain in the trust to be used by the trust as working capital etc.  The actual funds do not have to be transferred between entities.

Please refer:

https://www.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/FCAFC/2025/15.html

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