The High Court’s decision in Commissioner of Taxation v Bendel [2026] HCA 18 (“Bendel”) is a landmark development for the taxation of trusts and private groups. It brings to an end almost two decades of debate around the ATO’s view on the treatment of unpaid present entitlements (“UPEs”) in the context of Division 7A. In […]
Key points Value is driving share gains amongst Chinese brands, not a surge in EV demand The biggest shift is in mid-market SUVs ($35,000–$55,000) Market share is being taken from Toyota, Mazda and Mitsubishi Why this is not an EV boom Performing an analysis of the last 16 months VFACTS data, it has become evident that the Chinese OEM share […]
Key points Leaving Australia doesn’t automatically eliminate CGT. Australia’s deemed disposal rules (CGT event I1) often trigger a tax liability when residency changes, and even if deferred, the gain typically remains within Australia’s tax net. Timing and structure matter more than simply relocating. Moving overseas just before a sale rarely improves the outcome, as non-residents […]
In this episode, Frank discusses the pressures facing middle market businesses as they grow, the moments when financial complexity outpaces what the business is set up to handle. Sharing what he sees on the ground, the triggers that force business owners to act, the hidden costs of getting the finance function wrong, and what separates the businesses that build lasting financial […]
Key points The minimum tax is built on the false assumption that affected trusts can restructure; for many property businesses, stamp duty makes this commercially impossible. The ATO’s existing guidance on trust corporatisation actively conflicts with the Government’s proposed solution, leaving legitimate businesses with no workable pathway. Effective reform requires genuine coordination between Treasury and […]
The Treasurer’s 2026–27 Federal Budget delivers a significant overhaul of Australia’s tax system, fundamentally reshaping how middle market businesses invest, structure and grow. While the measures will be phased in over the coming years, the scale and complexity of the changes mean businesses and investors face a critical period of assessment and potentially, change in response […]
Summary of key dates for tax reform announced in the Federal Budget 2026-27. Taxation of discretionary trusts Measure Effective date Explanation Minimum 30% tax on discretionary trust distributions 1 July 2028 30% tax liability payable by the trustee on all discretionary trust distributions. Beneficiaries (other than corporate beneficiaries) receive a non-refundable tax credit. Capital Gains […]
From 1 July 2028, trustees will pay a minimum tax of 30% on the taxable income of discretionary trusts that is distributed to beneficiaries. This tax will operate as a minimum tax at the trustee level. Beneficiaries, other than corporate beneficiaries, will receive non-refundable credits for the tax payable by the trustee. At a high […]
Pre-CGT assets The Government has announced a significant change to the capital gains tax (CGT) treatment of assets acquired on or before 19 September 1985. From 1 July 2027, these assets will no longer be fully exempt from CGT. Instead, capital gains arising after that date will become taxable, while gains accrued before 1 July […]
From 1 July 2027, the Government will limit the ability to negatively gear residential investment properties purchased from 7.30pm on 12 May 2026 other than new builds. Arrangements in relation to existing residential properties will be grandfathered. Negative gearing occurs where the income earned from property is less than the expenses incurred (for example, interest, […]
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