The Federal Budget 2026–27 introduces a series of proposed tax and structural changes that may influence how wealth is accumulated, held and ultimately realised over time. For those working in the resources sector, these measures are particularly relevant given the prevalence of executive share schemes, business ownership structures, property investment and long‑term growth assets held outside superannuation.
For Mining and Resources executives, professionals and business owners, financial planning is rarely about short‑term outcomes. Career progression, equity participation, business ownership and capital‑intensive investment decisions typically unfold over long cycles, making structure, timing and strategy critical. Decisions made today often interact with future liquidity events, market cycles and legislative change, increasing the importance of integrated, forward‑looking planning.
This commentary is general information only and does not consider your objectives, financial situation or needs. These measures are proposals and may change as legislation progresses.
1. The defining change: Capital gains tax reform from 1 July 2027
At the centre of this Budget are proposed reforms to capital gains tax (CGT) that would fundamentally change how long‑term investments are taxed¹.
From 1 July 2027, the Government proposes to replace the current 50% CGT discount for assets held longer than 12 months with a CPI‑based cost base indexation method. Under this approach, the cost base of an asset would be increased by inflation so that only real gains are taxed. A minimum tax rate of 30% would then apply to capital gains accrued from that date, subject to specific exemptions.
Why this matters
For many years, the CGT discount has materially shaped investment behaviour, often favouring long‑term growth assets held in personal names or discretionary trusts. Moving from a discount to an indexation model, combined with a minimum tax rate, changes after‑tax outcomes and may alter which structures and environments are most effective for holding growth assets.
Importantly, the proposals include transitional arrangements. For assets owned before 1 July 2027 and sold after that date, gains accrued up to 30 June 2027 would continue to be assessed under existing rules (including the 50% capital gains tax discount and no minimum rate of tax applying), while gains accrued from 1 July 2027 onward would be assessed under the new methodology (indexation method, with a minimum 30% on capital gains). This introduces valuation and record‑keeping considerations that will matter in practice.
There are also notable exclusions. Based on the technical material released with the Budget, companies and superannuation funds, including SMSFs, are not impacted by these CGT changes, and there are no changes to the main residence exemption or existing small business CGT concessions.
From a financial planning perspective, this is less about a single tax rate and more about strategy. Asset location, ownership structures and the balance between growth and income assets become even more important. For many clients, this will prompt a review of how portfolios are structured across personal names, trusts, companies and superannuation.
2. Executive Share Schemes: Impacts from 1 July 2027
The Budget papers do not propose direct amendments to the existing employee or executive share scheme legislation. However, the Treasurer has indicated that consultation will occur with small businesses and startups4, which may result in carve outs or refinements as broader tax measures progress through legislation.
For Mining and Resources executives with vested shares or equity interests, the practical impact arises not from changes to share scheme rules themselves, but from the proposed capital gains tax reforms applying from 1 July 2027.
Where vested shares are retained and later sold, capital gains realised from 1 July 2027 would be subject to the new CGT framework. This includes a shift from the current 50 per cent discount method to an inflation-based cost base indexation approach, along with the application of a minimum 30 per cent tax rate on capital gains accrued from that date.
Additional complexity arises for vested shares acquired prior to 1 July 2027 but not sold until after that date. In these cases, transitional rules are expected to apply, requiring gains accrued up to 30 June 2027 to be calculated under existing CGT rules, with gains accruing thereafter assessed under the new methodology. This introduces valuation, record keeping and timing considerations that will be particularly relevant for executives holding long term equity positions through multiple employment and vesting periods.
Given the prevalence of equity-based remuneration across the resources sector, executive share schemes should be reviewed alongside broader asset ownership and realisation strategies rather than in isolation.
3. Property investors: Negative gearing under pressure
The second major area of reform is residential property investment.
The Budget proposes to restrict negative gearing for established residential investment properties acquired from 7:30pm AEST on 12 May 2026ii. From 1 July 2027, losses on those properties would no longer be deductible against other income. Instead, losses could be carried forward and used against future residential property income, including capital gains on the sale of property.
What stays the same
- Existing residential investment properties held at the time of the Budget announcement are carved out and may continue to be negatively geared until sold.
- Residential properties purchased between Budget night and 30 June 2027 may be negatively geared during that period, but not from 1 July 2027.
- Newly built residential properties that add to housing supply may continue to be negatively geared before and after 1 July 2027.
- Commercial property and non‑property investments such as shares remain subject to existing tax arrangements (i.e. allow negative gearing to continue).
Planning implications
For many investors, negative gearing has been a key driver of property strategy and cash flow assumptions. Restricting this benefit for newly acquired established property reduces the tax leverage of that strategy and places greater emphasis on net cash flow, yield, and long‑term capital efficiency.
When combined with the proposed CGT changes, property decisions will increasingly need to be assessed alongside alternative investment strategies rather than in isolation.
4. Discretionary trusts: A minimum tax from 1 July 2028
From 1 July 2028, the Government proposes to introduce a minimum tax rate of 30% on the taxable income of discretionary trusts.
Under the proposal, trustees would pay tax at a minimum rate of 30%, with non‑corporate beneficiaries receiving non‑refundable credits for tax paid. The intent is to reduce the tax advantage of distributing income to beneficiaries on lower marginal tax rates.
There are important exclusions, including certain fixed and testamentary trusts, deceased estates, charitable trusts, special disability trusts and complying superannuation funds. However, many commonly used family and business discretionary trusts may be affected.
Rollover relief and restructuring
To support affected groups, the Budget proposes expanded rollover relief for three years from 1 July 2027, allowing small businesses and others to restructure out of discretionary trusts into alternative entities, such as companies or fixed trusts, without triggering immediate CGT.
This creates an opportunity window, but not a simple one. Trust restructuring often involves legal, tax and estate planning considerations, and the trust may still play an important role for control, asset protection and succession. Early planning is critical. We are yet to see whether state governments will provide stamp duty exemptions on restructuring, when involving property or business assets.
5. Personal tax and cash flow measures
While structural tax reform dominates the headlines, several personal measures may affect short‑term cash flow².
- Working Australians Tax Offset: A permanent $250 non‑refundable tax offset is proposed from 1 July 2027 for income derived from work, including wages and sole trader business income.
- $1,000 instant tax deduction: From 1 July 2026, eligible individuals may claim a standard deduction of up to $1,000 for work‑related expenses without receipts, with the option to claim actual expenses where they exceed this amount.
- Previously legislated tax cuts: The reduction of the lowest marginal tax rate from 16% to 15% from 1 July 2026, and to 14% from 1 July 2027, remains in place.
These measures offer modest relief but are unlikely to offset the longer‑term impact of the structural changes for higher‑income individuals.
6. Business owners: Investment timing and cash flow
For business owners, several measures are relevant from a planning and cash flow perspective¹.
- The $20,000 small business instant asset write‑off is proposed to become permanent from 1 July 2026 for businesses with aggregated turnover under $10 million.
- From 1 July 2026, companies with turnover under $1 billion would be able to carry back tax losses and offset them against tax paid in the previous two years, subject to limits.
- From 1 July 2028, eligible start‑up companies may access refundable offsets for early‑year losses tied to specified employment taxes.
These measures can influence decisions around investment timing, capital expenditure and funding strategy.
7. Superannuation, retirement and aged care
Superannuation was largely untouched in this Budget, particularly in relation to the proposed CGT changes. However, previously legislated measures, including Division 296³ for larger super balances, remain on the forward agenda.
The Budget also included additional funding and reforms across aged care and the Support at Home program, with changes to subsidies, care categories and access pathways over coming years. For clients planning retirement or supporting ageing parents, funding structures and timing remain key considerations.
What should you consider now
Based on the Budget measures and adviser commentary, we see six high‑priority conversations emerging for many clients:
- Reviewing asset ownership, accumulation and investment structures across personal names, trusts, companies and superannuation.
- Reassessing property investment strategies and cash flow assumptions in light of negative gearing changes.
- Reviewing long‑held assets ahead of 1 July 2027, particularly where future CGT outcomes may change.
- Evaluating the long‑term role of discretionary trusts and whether restructuring should be explored.
- Aligning business investment and asset purchase decisions with updated tax settings.
- Revisiting retirement, superannuation and aged care planning where circumstances are evolving.
The urgency of these considerations will vary. Clients with significant growth assets held outside superannuation, family groups using discretionary trusts, property investors considering new acquisitions, or business owners planning asset sales may wish to prioritise earlier review. Others, including clients with predominantly super‑based investments, fully grandfathered property holdings, or a primary focus on income rather than capital realisation, may have more time to monitor developments as legislation is finalised.
How we can help
While the Budget sets the policy direction, the practical outcomes will depend on the final legislation and supporting guidance. We are closely monitoring how the CGT changes, trust rules, rollover relief and transitional arrangements are ultimately implemented, and how they interact with existing investment, retirement and estate structures.
These proposals have significant implications for how wealth is built, protected and transitioned over time. While there is a lead‑in period before most measures take effect, the strategic work required can be substantial.
If any of the topics above are relevant to your circumstances, we encourage you to speak with your adviser at Resources Unearthed. A proactive review now can help position you well ahead of the key dates and provide clarity in an increasingly complex landscape. Contact Brett Cribb and James Marshall at +61 (0)7 3007 2000, or email contact@resourcesunearthed.com.au.
Important information: This article is general information only and may refer to proposed measures that are not yet law. It does not consider your personal circumstances. Before acting, please seek personal advice from a licensed financial adviser. Information is current as at 13 May 2026 and may change.
Stratus Financial Group and its advisers are Authorised Representatives of Fortnum Private Wealth Ltd ABN 54 139 889 535 AFSL 357306. This is general advice only and does not take into account your objectives, financial situation, or needs, so you should consider whether the advice is relevant to your circumstances. Always read the relevant Product Disclosure Statements (PDS) before making any financial decisions.
[1] Budget Paper No. 2 | Budget 2026–27
[2] Tax reform | Budget 2026–27
[3] Better Targeted Super Concessions is law | Australian Taxation Office
[4] Tax reform for workers, businesses and future generations | Prime Minister of Australia
