Can a Trust be a Shareholder of a Company who is also a beneficiary of that same trust? I have proposed the following structure; parts of this structure already exist, new entity is ABC Pty Ltd; - XYZ Trust has 100% shareholding in new company ABC Pty Ltd. It also owns 50% of a Trading Company LMN Pty Ltd which provides the trust with significant dividend income. - ABC Pty Ltd is also a beneficiary of the XYZ Trust. LMN Pty Ltd is not a beneficiary. - XYZ Trust also has a separate Corporate Trustee. - XYZ Trust invests in long term property, has the benefit of CGT discount. - ABC Pty Ltd invests in short term property developments, treats property as stock. - ABC Pty Ltd accumulates distributions from trust and pays only 30% tax. - Profits within ABC Pty Ltd are reinvested for further property development within the company. - At some point in the long term future ABC Pty Ltd will need to pay dividends to XYZ Trust. XYZ Trust then distributes dividends to all beneficiaries except ABC Pty Ltd. I can't see any UPE or Div7A issues, can you? Is this possible, can anyone see a hole in this scheme?