- The new rules treat a trust's CGT assets held at the end of 30 June 2027 as sold just before 1 July 2027 and bought back on 1 July 2027.
- The amount used is market value just before 1 July 2027, or an apportioning method if the trustee chooses it.
- Nothing is payable on 30 June 2027. The gain is deferred until the trust actually sells the asset or another CGT event happens.
- Trustees usually look at the goodwill of a business the trust runs, and any shares or units the trust holds.
- Your accountant or tax adviser decides which assets are caught and which method to use.
Why trusts are caught
From 1 July 2027 the 50% CGT discount is replaced for individuals, trusts and partnerships by cost base indexation and a minimum 30% tax on certain gains. Gains that built up before that date keep the old treatment.
To split the two periods, the law treats a trust's CGT asset held at the end of 30 June 2027 as sold just before 1 July 2027 and bought back on 1 July 2027. Broadly, the rule applies where at least one beneficiary could get the CGT discount on their share of a gain from the asset. The trust then has two parts to its gain when it eventually sells.
No tax falls due on 30 June 2027. Any gain or loss from the deemed sale is deferred until the trustee actually sells the asset, or another CGT event happens to it.
Market value or apportioning
The amount used for the deemed sale is either:
- the asset's market value just before 1 July 2027, or
- an amount worked out under an apportioning method, if the trustee chooses it.
The apportioning method was still being developed by the government in late 2026. The trustee does not have to choose until the trust's tax return for the year of the actual sale. A valuation is not required, but it may be useful where the value of a business or shares at the date matters. See market value or apportioning.
What a trustee may want valued
Each CGT asset of the trust is treated separately. For a business trust, the assets that usually carry the value are:
- Goodwill of a business the trust runs. This is often the largest CGT asset in a trading trust, and the hardest to prove later because there is no price to look up.
- Shares in a private company. A family trust often holds shares in the company that runs the business, or in a bucket company.
- Units in a unit trust. A trust may hold units in another trust that owns a business.
- A partnership interest. A trust can be a partner in a partnership business.
Many tangible business assets, such as plant and equipment, are depreciating assets and are generally dealt with under different rules. Assets acquired before 20 September 1985 (pre-CGT assets) have their own deemed sale at the same date. Your adviser identifies which assets matter for your trust. We value the ones you ask us to.
Trusts and companies together
Many family groups look like this: a discretionary trust owns the shares in a company, and the company runs the business. The company itself is not affected by the discount change, because companies never had the discount. The trust's shares in the company are trust assets, so the deemed sale can apply to them.
In that case the value needed is usually the value of the shares the trust holds. To get there, the valuer values the company's business, adjusts for debt, surplus cash and other assets, and then considers what the trust's shareholding is worth. A 100% holding and a 30% holding are not valued the same way. See companies and the 2027 CGT changes.
Keep the records from the time
The trustee may not need a figure until the asset is sold, which could be many years away. What matters now is keeping the evidence that existed around 30 June 2027:
- the trust's financial statements and tax return for the year ending 30 June 2027
- management accounts and a balance sheet at 30 June 2027
- the trust deed, unit register or share register as at the date
- customer lists, contracts, pipeline and staff details at the time
- budgets and forecasts that genuinely existed then
What the valuation report covers for this purpose
- the trust, the trustee, and the asset valued (goodwill, shares, units or interest)
- the date: 30 June 2027, just before 1 July 2027
- the purpose: the deemed sale and reacquisition for a trust under the new CGT rules
- market value as the standard of value, the method and a cross-check
- earnings, adjustments, evidence and what was known at the date
- assumptions, limitations, and the signature of the valuer responsible
What we need from the trustee
- the trust deed and a structure chart of the group
- which asset or interest you want valued
- financial statements for the trust and any company or trust whose shares or units are valued
- the date-specific records listed above
Get a fixed fee
The fee is fixed by the annual revenue of the business being valued, from $1,495 + GST for revenue under $1 million. A trustee can book a 30 June 2027 valuation now at 10% off, and we value after the date. Choose your revenue band below.
General information only, current at 10 November 2026. We value businesses and business interests; we do not give tax advice. Your accountant or tax adviser decides whether a rule applies to you.