Tax reform – introducing a minimum tax on discretionary trusts
The Government announced it will introduce a 30% minimum tax on discretionary trusts.
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: