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Selected cases

Federal Court of Australia · [2026] FCA 496

Chan v Moore

A Federal Court liquidation case about director loan accounts, cross-border related-party transfers and incomplete company books.

Federal Court of Australia24 Apr 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

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Quick read

  • Director loan accounts are only as useful as the records behind them.
  • A Federal Court liquidation case about director loan accounts, cross-border related-party transfers and incomplete company books.

Use this to check

  • Director loan accounts need bank, invoice and ledger support.
  • Family or related-company funding should be documented when the money moves.
  • Cross-border transfers can be hard to explain if the accounting records are incomplete.

Decision snapshot

  1. 1

    What happened

    • Integrated Natural Solutions Pty Ltd distributed Australian papaw ointment products overseas, including into Hong Kong.
    • After INS Australia was wound up in December 2021, its former sole director, Julia Chan, lodged a proof of debt in the liquidation.
    • She later claimed about $2.04 million, saying money sent from the related Hong Kong company to INS Australia should be treated as a capital contribution made by or for her and credited to her director loan account.
    • The liquidator disagreed.
  2. 2

    What the court had to decide

    • The Federal Court had to decide whether a $3.037 million related-party contribution from INS Hong Kong should be credited to Julia Chan's director loan account as a contribution made by or on her behalf, and whether the liquidator had proved that she instead owed INS Australia $996,085 on that account.
  3. 3

    What the court decided

    • The Court dismissed Julia Chan's amended originating process.
    • It found that she had not established the related-party contribution was made by or on her behalf, and that the cross-claimants had established that $996,085 was owing by her to INS Australia on the director loan account.
    • The parties were directed to confer on orders and costs.

Practical impact

Practical read

  • Director loan accounts are only as useful as the records behind them.
  • If related-party money moves across borders, through family members or between connected companies, the company books need to show exactly whose money it was and why it was paid.

Useful next steps

  • Director loan accounts need bank, invoice and ledger support.
  • Family or related-company funding should be documented when the money moves.
  • Cross-border transfers can be hard to explain if the accounting records are incomplete.
  • A proof of debt in liquidation may be rejected if the records do not support it.
  • Directors can face repayment claims where a loan account has a debit balance.

Practical read

This case is the nightmare version of messy related-party accounting. The company had overseas sales, family shareholders, related Hong Kong and Australian entities, a director loan account, invoices, bank transfers and incomplete books. After liquidation, the former director tried to turn a large flow of money into a creditor claim. The liquidator said the records did not support that story.

The Court treated the contemporaneous records as critical. It was not enough to say, after the company had failed, that money from a related company was really money contributed by the director through family loans. The ledgers did not reconcile properly with the bank and invoice records, and the late explanation was not supported by the documents the Court expected to see.

For small businesses, especially family companies and import/export businesses, the practical point is blunt. Related-party payments must be documented at the time. If a payment is a loan, capital contribution, repayment, customer receipt or intercompany transfer, the documents and accounts should say so while the business is alive, not years later in a liquidation fight.

Checks to run

Key points

  • Label every director loan, capital contribution and intercompany payment when it is made.
  • Reconcile director loan accounts to bank statements and invoices each month.
  • Keep written loan documents for family or related-party funding.
  • Do not mix personal, family and company explanations in the accounting file.
  • Get legal help before lodging a proof of debt based on related-party records.

Key takeaways

  • Director loan accounts need bank, invoice and ledger support.
  • Family or related-company funding should be documented when the money moves.
  • Cross-border transfers can be hard to explain if the accounting records are incomplete.
  • A proof of debt in liquidation may be rejected if the records do not support it.
  • Directors can face repayment claims where a loan account has a debit balance.

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