TRUSTS · PUBLISHED 23 SEPTEMBER 2026
Discretionary trust reform announced for 1 July 2028
The Government has announced a minimum 30% tax on the taxable income of discretionary trusts from 1 July 2028, subject to exceptions and implementation details.
What the proposal covers
Treasury says the minimum tax would be paid by trustees. Its consultation identifies exemptions for other trust types, including fixed trusts, complying superannuation funds, special disability trusts, deceased estates and qualifying testamentary trusts. Some classes of income are also proposed to be excluded.
Why an early review helps
Trustees can document the trust’s purpose, beneficiaries, income sources and current distribution practices. Families and businesses considering changes should model the full tax and legal effect, including possible state duty and capital gains implications, before altering an existing structure.
Transitional arrangements
Treasury has announced three years of rollover relief from 1 July 2027 for eligible restructures. The precise conditions and interaction with other taxes require review against the final rules. A change of structure should not be assumed to qualify automatically.
Sources: Treasury — 2026–27 tax system changes; Treasury Ministers — implementation consultation. This article describes government announcements as at 23 September 2026. Final law and eligibility must be checked before acting.