16/06/2026
๐ต๐ฌ๐ฌ,๐ฌ๐ฌ๐ฌ ๐๐๐๐๐ฟ๐ฎ๐น๐ถ๐ฎ๐ป ๐ณ๐ฎ๐บ๐ถ๐น๐ ๐๐ฟ๐๐๐๐. ๐ข๐ป๐ฒ ๐บ๐ฎ๐๐๐ถ๐๐ฒ ๐ฟ๐ฒ๐ด๐๐น๐ฎ๐๐ผ๐ฟ๐ ๐ฟ๐ฒ๐๐ฟ๐ถ๐๐ฒ.
The Federal Budget has introduced a proposed 30% minimum tax on discretionary trusts - completely altering the future of family wealth planning alongside the ATO's aggressive stance on Section 100A.
If you operate your business or investments through a trust, the rules of the game are shifting. Here is the breakdown:
๐ ๐ง๐ต๐ฒ ๐ก๐ฒ๐ ๐ฏ๐ฌ% ๐ง๐ฟ๐๐๐ ๐ง๐ฎ๐
๐๐น๐ผ๐ผ๐ฟ (๐ฃ๐ฟ๐ผ๐ฝ๐ผ๐๐ฒ๐ฑ ๐ณ๐ฟ๐ผ๐บ ๐ญ ๐๐๐น๐ ๐ฎ๐ฌ๐ฎ๐ด)
The Government has announced a 30% minimum tax rate on the taxable income of discretionary trusts.
โ The Death of Low-Rate Income Splitting:
Distributing to adult children, university students, or low-income family members to use their lower marginal tax brackets will no longer bypass the 30% tax floor.
โ Non-Refundable Credits:
While individual beneficiaries get a credit for the tax the trustee pays, it is non-refundable. If their personal tax rate is lower than 30%, the excess is completely lost.
โ The Bucket Company Trap:
Corporate beneficiaries are slated to be excluded from receiving these tax credits. Distributing to a bucket company could trigger severe double-taxation, potentially dragging effective rates over 60%.
๐ ๐ง๐ต๐ฒ ๐๐๐ฟ๐ฟ๐ฒ๐ป๐ ๐ง๐ต๐ฟ๐ฒ๐ฎ๐ - ๐ฆ๐ฒ๐ฐ๐๐ถ๐ผ๐ป ๐ญ๐ฌ๐ฌ๐ & ๐๐ถ๐๐ถ๐๐ถ๐ผ๐ป ๐ณ๐
You don't have to wait until 2028 for the tax landscape to get complicated. The ATO is already actively auditing current and past distributions:
โ ๏ธ It targets "reimbursement agreements" where income is distributed on paper to a low-tax beneficiary, but the actual money is funneled to someone else.
โ ๏ธ If hit, the ATO cancels the distribution and taxes the trustee at the top marginal rate (47%).
โ ๏ธ Unpaid Present Entitlements (UPEs) to companies continue to be strictly monitored under Division 7A loan rules.
๐ผ ๐ช๐ต๐ฎ๐ ๐๐ต๐ถ๐ ๐บ๐ฒ๐ฎ๐ป๐ ๐ณ๐ผ๐ฟ ๐๐ผ๐๐ฟ ๐ฏ๐๐๐ถ๐ป๐ฒ๐๐:
Family trusts aren't broken - but the standard "copy-paste" distribution strategies used for the last decade are officially dead.
With transitional "restructure rollover relief" proposed to open on 1 July 2027, many business owners will need to evaluate whether they should pivot to alternative structures (like companies or fixed trusts) or completely overhaul their distribution minutes before the deadlines.
Before you sign your next EOFY trustee resolutions, your trust framework needs an expert review. Let's look at your structure before the window closes.
๐ ๐ฌ๐ฐ๐ด๐ญ ๐ฑ๐ฑ๐ณ ๐ฐ๐ต๐ฌ
๐ ๐ฑ๐ถ๐ฎ๐ด๐ป๐ผ๐๐๐ถ๐ฐ๐ฎ๐ฐ๐ฐ๐ผ๐๐ป๐๐ถ๐ป๐ด.๐ฐ๐ผ๐บ.๐ฎ๐