Does the 30 June 2027 CGT rule apply to units in a unit trust?

The rule follows the unitholder

The 30 June 2027 rule comes from the Treasury Laws Amendment (Tax Reform No. 1) Act 2026. From 1 July 2027, individuals and trusts lose the 50% CGT discount on gains that build up after that date, and cost base indexation applies instead. To protect the discount on the gain built up before then, the law treats certain assets as sold just before 1 July 2027 and bought back on 1 July 2027 at market value. Units in a unit trust are CGT assets, so the question is who holds them.

Where the rule applies, it applies automatically. No tax is payable in 2027 because of it. The gain up to that point waits until the units are actually sold, and the 50% discount can apply to that earlier part if the usual conditions are met, including the 12 month holding rule.

Two layers: the units and what the trust owns

A unit trust that runs a business, or holds shares in the company that does, is a trust in its own right. Having a company as trustee does not change that. So the same rule can also reach the trust's own assets, such as goodwill or shares in an operating company, in the trustee's hands.

For the trustee, the test is whether at least one unitholder could make a discount capital gain. If every unitholder is a company or a super fund, the trust's own assets may fall outside the rule even though the trust runs a business. That is our reading of the Act, not advice. Your tax adviser should confirm it for your trust.

If market value is used for the units

Market value is the default under the rule, but it is not the only path. The Act lets the Minister set an apportioning method instead. In October 2026 that method was still a draft released for consultation, and the choice is made later, with the tax return for the year the units are sold. Which path suits you is a question for your tax adviser.

Where market value is used, a unit's value usually starts with what the trust owns, including the business, less what it owes. A valuer then reads the trust deed: income and capital rights, redemption terms and any limits on transfer. The size of the holding matters too. A minority parcel without control is often worth less per unit than a controlling holding, because a buyer pays for what the units let them do.

Independent Business Valuation values units in unit trusts and the business behind them, and each report is signed by a suitably qualified business valuer at Valuo. Where both layers need a value, we scope them in one engagement. We charge one fixed fee of $999 + GST for a full valuation report on one business or ownership interest with annual turnover under $10 million. Each additional entity or interest is $795 + GST. The fixed fee applies once we confirm the interest, purpose, structure and records fit the fixed-fee scope. Anything outside it is quoted in writing before we start. A valuation as at 30 June 2027 is prepared after that date, once your records to 30 June 2027 are available. You can book your place now.