Section 100A and trust distributions: how to stay ATO-safe without an accountant
A plain-English explanation for trustees who want clean, defensible records.
Bottom line: Section 100A is about ensuring trust distributions are real, documented, and paid as intended. If you record distributions clearly, keep supporting notes, and avoid circular arrangements, you can stay compliant without drama. Use the tax minimisation simulator to understand the benefit you are protecting.
This is general information only. If your trust is complex or you are unsure, seek professional advice.
What Section 100A is really about
Section 100A targets arrangements where distributions are declared on paper but the money never reaches the beneficiary in a genuine way. The ATO focuses on “reimbursement agreements” and whether a beneficiary receives a genuine benefit.
Three behaviours to avoid
- Back-to-back transfers: Money is distributed then immediately returned.
- Undocumented loans: Distributions are “loaned” without proper terms.
- Hidden benefits: A beneficiary is named but another person receives the benefit.
How to stay ATO-safe
- Make resolutions before June 30: Document who receives what.
- Record the flow of funds: Keep distribution statements and bank evidence.
- Maintain notes: A short explanation of why each distribution was made.
- Keep it consistent: Avoid “reversing” distributions without reason.
DIY trust compliance checklist
- Distribution resolution signed and dated.
- Beneficiary statements prepared.
- Payments made or properly documented.
- Supporting notes stored in your records.
When to get professional help
If your trust has multiple entities, related-party loans, or unusual distributions, professional review is sensible. DIY works best for clean, routine structures.
About the author
Written by the Self Managed team based on practical trust compliance experience.
Last updated
January 2026