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28 Sept 2025

I have a client structure as follows:

  • Family trust A operating a business with a turnover of less than $10M
  • Individual B holds 50% and Company C holds another 50%
  • Company C is a bucket company

Scenario

In 2025-26, Trust A distributed taxable trading profits of $100K to the Individual and the remaining $100K to Company C from $200K. Company C's only income is that distribution.


Would Company C be considered a Base Rate Entity and taxed at 25% or would the company pay the 30% tax rate?


If I am not wrong, the Distribution from the operating business of Trust A is Active Income and carries the same nature.


A company will generally be treated as a base rate entity and be subject to the lower corporate tax rate if:

  • Its aggregated annual turnover in the relevant income year is less than $50m; AND
  • No more than 80% of its assessable income for the year is BREPI.

Here, Company C clears both conditions.


Still, the question is: Would Company C be considered a Base Rate Entity and taxed at 25% or would the company pay the 30% tax rate?

1,216 views
1 replies
1,216 views
1 replies

Most helpful response

Most helpful reply

NikkiATO(Community Moderator)Community Moderator
30 Sept 2025

Hi @Problemhere,


Company C should qualify for the 25% tax rate as a base rate entity if:

  • its aggregated turnover is under $50 million, and
  • no more than 80% of its income is base rate entity passive income (BREPI).

Since Trust A runs an active business, the $100K trust distribution to Company C would usually keep its character as active business income. This means it wouldn’t count as passive income (BREPI).


If this is Company C's only income and its turnover is under the limit, it should meet the conditions for the lower tax rate.

All replies

Most helpful reply

NikkiATO(Community Moderator)Community Moderator
30 Sept 2025

Hi @Problemhere,


Company C should qualify for the 25% tax rate as a base rate entity if:

  • its aggregated turnover is under $50 million, and
  • no more than 80% of its income is base rate entity passive income (BREPI).

Since Trust A runs an active business, the $100K trust distribution to Company C would usually keep its character as active business income. This means it wouldn’t count as passive income (BREPI).


If this is Company C's only income and its turnover is under the limit, it should meet the conditions for the lower tax rate.

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