Key points: The proposed minimum trust tax could reshape how family groups structure wealth, investments and succession planning. For many discretionary trusts, the biggest question is whether existing structures remain fit for purpose. Early consideration may provide greater flexibility if the reforms proceed. The Federal Government has released exposure draft legislation introducing a proposed minimum […]
This webinar explores the Federal Government’s proposed 30% minimum tax on discretionary trusts and why it could be one of the most significant tax changes affecting private groups in recent decades. Hosted by Melbourne Partner Yina Tang, the session features Partner Alexis Kokkinos, a leading voice in the consultation process with Treasury and the ATO. […]
Treasury recently released exposure draft legislation containing further amendments to the Government’s capital gains tax and negative gearing reforms. These reforms introduced a fundamentally new framework for taxing capital gains, including complex transitional rules for assets held before 1 July 2027. The exposure draft seeks to address a range of technical, integrity and implementation issues […]
Welcome to Pitcher Perspective, where we take you beyond the headlines and go in-depth on the current issues affecting the Australian businesses. ATO reviews are becoming more common, and for many growing businesses and wealthy families, they’re no longer a question of if but when. In this episode, Private Wealth Partner Jordan Kennedy is joined […]
Hiro has built his career at Pitcher Partners since joining in 2016 and specialises in delivering fully outsourced CFO solutions and advisory services to Australian and offshore entities of Japanese multinational groups. His expertise spans tax compliance, financial reporting, and broader business advisory, enabling him to provide integrated and practical support across the full business […]
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 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 […]
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