An amalgamated loan occurs when a private company (Pty Ltd) makes one or more loans to an entity during an income year, each of which has:
1. Same maximum term;
2. Would be treated as a Division 7A dividend in that year if it was for the section 109N exemption;
3. Not fully repaid by the company's lodgment day for that year.
The loans will be brought together at the end of the year to form a single 'amalgamated loan'
Section 109Q of Income Tax Assessment Act 1936 (ITAA 1936) gives the commissioner the authority to have the loan not treated as a dividend provided certain conditions are met. Much like Section 109N of ITAA 1936.