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Tax reform – introducing a minimum tax on discretionary trusts

The Government announced it will introduce a 30% minimum tax on discretionary trusts.

Last updated 12 May 2026

On 12 May 2026, as part of the 2026–27 Federal Budget, the Government announced it will introduce a 30% minimum tax on discretionary trusts from 1 July 2028.

This measure is not yet law.

The minimum tax will apply at the trustee level. Non-corporate beneficiaries who are presently entitled to a share of the net income of the trust will be able to claim a non-refundable income tax credit for the tax paid by the trustee on that income.

The Government will also introduce a time limited (3 years) restructure rollover with this measure. The proposed rollover relief will:

  • be available from 1 July 2027
  • facilitate the transfer of assets out of discretionary trusts to entities that are not discretionary trusts.

For more information, see:

QC107302