My uncle wishes to loan his sons Unit Trust money for the purchase of a factory in which they run their business. Approx. $1-2million.
He wishes to charge them a nominal amount of fixed interest (approx. 3.25%).
He would declare the interest earned in his tax return but after tax the amount will give him a comfortable amount to live off. He is a self funded retiree.
Are there tax implications or could this be construed as avoidance if he is not charging commercial interest rates?