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Property Tax Changes · Koste Knowledge Base

Do trusts get the CGT discount or indexation?

Quick Answer

Discretionary trusts can pass the 50% CGT discount through to individual beneficiaries, but companies receiving trust distributions do not get the discount. Under proposed indexation changes, the position for trusts is less certain.

CGT discount and indexation for trusts

The tax treatment of capital gains in a trust is more complex than for individual investors. Whether your trust can access the CGT discount — or indexation under proposed changes — depends on the type of trust, the type of beneficiary, and the final legislative design.

Current law: the 50% CGT discount via pass-through

Under current law, a discretionary trust that sells an asset held for more than 12 months generates a capital gain eligible for the 50% discount. However, the trust itself does not apply the discount — instead, the discount is passed through to the individual beneficiary who receives the distribution.

How it works:

  • The trust sells a property with a $400,000 capital gain
  • The trust resolves to distribute this gain to an adult child beneficiary
  • The beneficiary applies the 50% discount to get $200,000 in their hands
  • The beneficiary pays CGT on $200,000 at their marginal rate
  • This pass-through mechanism means individual beneficiaries get the discount; companies (which do not qualify for the discount) do not get it when they receive trust distributions.

    What changes under proposed indexation

    Under the proposed replacement of the CGT discount with indexation, the position for trusts is unclear as of mid-2026. Key questions include:

    • Will trusts be able to index the cost base of property before distributing gains to beneficiaries?
    • Will individual beneficiaries still apply indexation to their trust-sourced gains?
    • How will the 30% minimum tax apply to trust distributions of capital gains?
    These details are subject to final legislative design and have not been confirmed.

    Companies as beneficiaries

    A company that receives a capital gain distribution from a trust does not qualify for the 50% CGT discount (companies are excluded). Under indexation, whether companies can index gains is also not yet confirmed. This is a consideration if your trust has a corporate trustee or beneficiary intended to receive capital gain distributions.

    Summary

    • Individuals receiving trust capital gain distributions: currently get 50% discount, future uncertain
    • Companies receiving trust capital gain distributions: no discount, future uncertain
    • Trust losses (including from negative gearing): quarantined, cannot be distributed
    Seek specialist advice for trust structures given the complexity and the unsettled nature of proposed changes.

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    Written by Koste Team · Koste Chartered Quantity Surveyors · AIQS Member · RICS Member · TPB Registered · 1300 669 400 · info@koste.ai