From 1 July 2028
The proposed minimum-tax framework is intended to commence from 1 July 2028.
2028 Discretionary Trust Changes
Using a discretionary trust?Proposed 2028 changes may affect your structure.
Draft tax changes proposed from 1 July 2028 could affect how some Australian businesses use discretionary trusts, corporate beneficiaries and bucket companies.
You do not need to assume a restructure is required. Start by understanding whether the proposed changes are relevant to your current position.
Take the Trust Impact Check
Around 2–3 minutes • No obligation
Watch Zac explain why the proposed changes may be worth reviewing.
Simple first stepUnderstand whether the issue may be relevant before making decisions.
Business-focusedDesigned for Australian business owners using discretionary trusts.
No pressureThe initial Trust Impact Check is free and takes around 2–3 minutes.
Why this matters
What is being proposed?
Exposure-draft legislation has been released for proposed changes affecting discretionary trusts. The detail matters — and the potential outcome will not be the same for every trust.
30% minimum-tax framework
The draft proposes a 30% minimum tax on discretionary trusts, subject to the legislation’s rules, exclusions and implementation details.
Different pathways may apply
Exclusions, elections, transition arrangements and structural options may affect how the proposed rules apply in different circumstances.
Important: The measures are still proposed and may change through the legislative process. This page does not imply that every trust will pay 30% or that every business needs to restructure.
Who should pay attention
Could this be relevant to your structure?
You may want to understand the proposed changes more closely if one or more of the following sounds familiar.
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Operate through a discretionary trust
Your business currently uses a discretionary or family trust structure.
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Use a bucket company
Trust income may be distributed to a corporate beneficiary.
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Distribute surplus income
Your trust forms part of how business profits are distributed.
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Generate meaningful taxable profits
Your structure is actively used as part of your tax and business strategy.
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Expect to continue beyond 2028
You intend to keep operating under your existing structure.
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Are already reviewing your structure
You are considering whether your current arrangements still suit the business.
Take the Trust Impact Check
If one or more of these sounds familiar, the check can help identify whether a closer review may be worthwhile.
Bucket company focus
Does your trust distribute income to a bucket company?
If your discretionary trust distributes income to a corporate beneficiary, the proposed changes may be particularly relevant to the way your existing strategy operates.
That does not automatically mean your current strategy is wrong. It means the potential impact should be understood before structural decisions are made.
Check Your StructureBUSINESS
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DISCRETIONARY TRUST
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CORPORATE BENEFICIARYOften referred to as a bucket company
Don’t restructure because of a headline.
Different businesses may have different outcomes depending on their structure, beneficiaries, income, corporate beneficiaries and long-term plans. The right starting point is understanding your current position — not assuming that one response is right for every trust.
Start here
BWC Trust Impact Check
Answer a few short questions about your current structure to help identify whether the proposed changes may warrant a closer review.
Around 2–3 minutesQuick to complete
No obligationUnderstand your position first
Clear next stepSee whether a closer review may be worthwhile
The Trust Impact Check provides an initial indication only and is not tax, legal or financial advice.
Understand your potential impact.
The check will ask a few practical questions about how your current structure operates.
A clear path
What happens after the check?
No jump straight into a restructure. The funnel is designed to help you understand relevance first, then decide whether a closer review is warranted.
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Complete the Trust Impact Check
Answer a few questions about your existing structure.
02
Understand your potential relevance
Your answers help identify whether the proposed changes may warrant closer consideration.
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Review your position if required
Where appropriate, you can proceed to the BWC Trust Impact Review.
For businesses needing a closer look
BWC Trust Impact Review
$495 + GST
For businesses that appear to need a more detailed assessment, the BWC Trust Impact Review provides a structured look at your existing position and potential options.
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Current structure mapA clear picture of how your existing business and trust arrangements fit together.
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Indicative impact comparisonAn assessment of how the proposed changes may interact with your current position.
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Bucket-company exposure reviewWhere relevant, consideration of the role of corporate beneficiaries in your structure.
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Potential options summaryUnderstand the pathways that may warrant further consideration.
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45-minute review meetingWalk through the findings and discuss what they may mean for your business.
Fee credit: If you proceed with an eligible full Structure Strategy within 30 days, the $495 review fee will be credited toward that engagement.
Book Your Trust Impact Review
Not sure you need one? Take the Trust Impact Check first.
Why BWC
Clarity before change.
Business structures are rarely one-size-fits-all. BWC helps business owners understand the commercial and tax implications of their existing arrangements before making significant structural decisions.
Understand the position. Compare the options. Then decide what comes next.
Add only BWC credentials, memberships, adviser qualifications or testimonials that have been verified and approved for use.
Frequently asked questions
Questions before you start?
Are the proposed 2028 trust changes already law?
No. Exposure-draft legislation has been released, but the measures remain subject to the legislative process and may change before commencement.
Does every discretionary trust need to restructure?
No. The potential impact depends on the circumstances of the trust and its beneficiaries, income, distributions and existing structure. The Trust Impact Check is designed to help identify whether a closer review may be worthwhile.
What is a bucket company?
A bucket company is a company used as a corporate beneficiary of a trust and may receive distributions of trust income.
Does using a bucket company mean my structure is wrong?
No. The proposed changes may alter outcomes for some arrangements, but that does not mean every structure involving a corporate beneficiary should be changed.
What does the Trust Impact Check cost?
Nothing. The initial Trust Impact Check is free and takes approximately 2–3 minutes.
Is the Trust Impact Check tax advice?
No. It is an initial indication designed to help identify whether your circumstances may warrant further review. It does not replace advice based on your complete circumstances.
What is included in the $495 + GST Trust Impact Review?
The review includes your existing structure map, an indicative impact comparison, relevant bucket-company exposure, a potential-options summary and a 45-minute review meeting.
What happens if I need more detailed advice?
If a broader Structure Strategy is appropriate, BWC can discuss that separately after the initial assessment. If you proceed with an eligible Structure Strategy within 30 days, the $495 review fee is credited toward that engagement.
Start with clarity
Know where your trust stands before deciding what comes next.
Start with the short BWC Trust Impact Check and understand whether the proposed 2028 changes may warrant a closer review of your structure.
Take the Trust Impact Check
Around 2–3 minutes • No obligation