A trust where the trustee has discretion to distribute income and capital each year to any beneficiary listed in the deed - usually streamed to whichever beneficiary is on the lowest marginal rate that year.
The proposed Trust Minimum Tax from 1 July 2028 caps the streaming advantage: the trust group pays whichever is higher - beneficiary tax or 30% of net trust income. A restructure-relief window (July 2027 to June 2030) lets trusts convert without the floor biting. Trust losses cannot be distributed and carry forward inside the trust.