Tax Insight · CGT

CGT Reform for ETFs and Managed Funds: AMIT Cost Base + 1 July 2027 Rules

Published
May 2026
Last reviewed
Tax-year context
Current
Reading time
29 min

General information only — we maintain pages with primary-source checks and date-based reviews. See editorial policy.

CGTFederal Budget 2026Capital GainsETFsManaged FundsAMITInvesting

Model your gain under the 2027 CGT reform

Compare selling under the legacy 50% discount against holding under CPI cost-base indexation + the 30% minimum tax — for your asset, income and sale date.

If you hold and sell later
Enter acquisition date, cost base, current value and income to compare your options.

General information only. This is not tax or financial advice. Consult a registered tax agent for advice specific to your situation.

The CGT reform announced in Budget 2026 is now law — it passed Parliament on 25 June 2026 and received royal assent on 26 June 2026 as the Treasury Laws Amendment (Tax Reform No. 1) Act 2026 (No. 49) and the Income Tax Rates Amendment (Tax Reform No. 1) Act 2026 (No. 50). From 1 July 2027 the 50% CGT discount is abolished for individuals, partnerships and trusts, replaced with cost base indexation plus a 30% minimum tax on real gains. The reform applies to individuals, partnerships and trusts — the typical holders of ETF and managed fund units. If you hold units in Vanguard, BetaShares, iShares, BlackRock, VanEck, or any of the established Australian-domiciled ETF or unit-trust products, the reform reaches you through two CGT pathways, not one. This article works through both, the ETF cost base adjustments (under the AMIT rules) that sit underneath them, and the foreign-asset-ETF edge cases.

The short version: Your Australian ETF distributions in 2026-27 still get the 50% discount. From 1 July 2027, both the gains your ETF passes through to you AND your own sale of ETF units get the new rules.

For the underlying mechanics of the reform itself — three-bucket transition, indexation, 30% minimum — read the master article first: 50% CGT Discount Reform: Cost Base Indexation + 30% Minimum Tax from 1 July 2027.

Timeline — when the reform hits your ETF holdings

The reform is calendar-driven from start to finish. Because ETFs sit on top of an underlying portfolio of assets, the dates that matter are not just “when you sell” — they are the boundary date, the first reform-era distribution, and the first tax return that has to apply the new split treatment. Skim this before reading the rest of the article.

DateWhat happensWhat it means for you
12 May 2026Budget 2026 announces the reform.Most ETFs hold underlying assets across years — fund managers begin tracking acquisition dates more carefully so they can label distributed gains correctly later.
25–26 June 2026Reform passes Parliament (25 June) and receives royal assent (26 June) — Acts No. 49 and No. 50 of 2026.The rules in this article are enacted law, not a proposal. Plan with certainty.
2026-27 income year (1 Jul 2026 – 30 Jun 2027)Last FY where ETF unit disposals and distributed gains both get the full 50% discount.Both your own unit sales and your AMIT distribution statements still use legacy rules for this entire year — last chance for the clean 50% across both pathways.
30 June 2027 (Wednesday)Last day for ETF unit disposals wholly under the legacy regime.The CGT event date for an on-market unit sale is the trade date, so trading by 30 June 2027 captures the 50% discount on the full gain. No panic either way — units still held get the deemed-sale split, preserving the discount on gains accrued to this date.
1 July 2027Reform start: cost base indexation + 30% minimum tax begin.Units bought from this day are Bucket C; units owned before are Bucket B (split treatment). AMIT statements for FY2027-28 will need to label distributed gains by underlying disposal date.
From 1 July 2027AMIT distribution statements need new structure.Fund managers (Vanguard, BetaShares, iShares, VanEck, BlackRock) will track each underlying disposal’s date so they can correctly label the legacy vs reform portions of any distributed capital gain. DRP reinvestments from this day forward are all Bucket C parcels.
First distribution after 1 July 2027 (typically late Sep / Dec 2027)First “split-labelled” AMIT statement.Your annual tax statement will, for the first time, separate distributed gains into legacy and reform components — expect a new line item on your AMMA.
30 June 2028End of FY2027-28 — first full reform year.The annual AMIT tax statement (AMMA) covering this period will fully reflect the new structure across both unit disposals and distributed gains.
31 October 2028First tax return applying reform rules to ETF distributions.Self-lodging individuals filing 2027-28 returns will use the new split-treatment system for both unit disposals and distributed gains. Tax agents get the usual lodgement-program extension; the math is the same.
1 July 204215 years post-reform.By this point, the majority of widely-held ETFs (VAS, VGS, VAP, IVV) will have decade-plus parcels straddling the 1 July 2027 line — making cost base records (CHESS statements, DRP confirmations, every AMMA in between) critical. Reconstructing them from broker records 15 years on is painful.

How time changes your tax bill

ETF investors have a unique time profile. Most are buy-and-hold (10+ years), often DRP’d, and the AMIT cost-base creep means cost basis drifts every year. Unlike direct shares where you usually have a single buy-date and a single sell-date, an ETF holding is a living thing — parcels stack up year after year, distributions adjust your cost base annually, and the fund itself realises gains underneath you. Time interacts with the reform in four directions: holding period across 1 July 2027, years past reform date, fund growth rate, and AMIT cost-base adjustments accumulating each year.

Holding-period split — typical ETF buyer

Most ETF holders buy in tranches over 5–15 years. The legacy-vs-reform share of any single parcel’s gain depends linearly on how much of the hold sat on each side of the boundary. Worked table for a single $30,000 nominal gain parcel:

BoughtSoldHold (yrs)Legacy shareReform shareComment
1 Jul 20221 Jul 20321050.0%50.0%Even split
1 Jul 20171 Jul 20321566.7%33.3%Legacy dominates
1 Jul 20251 Jul 20351020.0%80.0%Reform dominates — short pre-hold
1 Jul 20301 Jul 2040100%100%Bucket C — pure new rules

For DRP holders, the apportionment is per-parcel — a 15-year DRP’d VAS holding contains ~30 separate parcels each with its own buy-date and split. The reform doesn’t apply once at the unit-holding level; it applies thirty times at the parcel level, each with its own legacy/reform ratio.

Indexation by years past reform (2.5%/yr CPI)

Once a parcel falls into Bucket C (or the reform portion of Bucket B), its cost base is uplifted by CPI each year. Same baseline as other asset classes:

Years past 1 Jul 2027Cost base uplift
3 yrs7.7%
5 yrs13.1%
10 yrs28.0%
15 yrs44.8%

ETF holders typically hold longer than direct-share investors, so indexation has more time to compound. For broad-index ETFs (e.g. VAS, A200) with 8–10%/yr historical nominal returns, the indexation uplift offsets only part of the gain. For property/infrastructure ETFs (VAP, IFRA) running 5–7%/yr, indexation can absorb a larger share — sometimes most of the nominal growth in a low-yield year.

ETF type sensitivity — three scenarios

The reform’s bite depends on what your ETF actually holds. Sample $35,000 nominal gain over a 10-year hold (5 yrs pre + 5 yrs post 1 July 2027):

ETF typeAnnual nominal returnOld-rules tax (37% MTR)New-rules tax (37% MTR)Diff
Broad equity (VAS, A200)9%/yr$6,475~$7,180+11%
Property/infrastructure (VAP, IFRA)6%/yr$6,475~$6,140−5%
Foreign-asset growth (VGS, NDQ)11%/yr$6,475~$7,560+17%
Diversified balanced (DZZB, VDBA)7%/yr$6,475~$6,470~0%

Plain-English: broad-equity ETFs and foreign-growth ETFs come out worse under the reform; property/infrastructure ETFs come out better; balanced ETFs are roughly neutral. The tax outcome flips depending on what your ETF holds. The crossover sits roughly where the nominal return equals indexation (2.5%) + the discount-equivalent rate — above that, reform stings; below, indexation absorbs the gain.

AMIT cost-base creep — silent time-drag

Each year, your ETF’s AMIT tax statement adjusts your cost base. Property and infrastructure ETFs typically distribute large tax-deferred components (return of capital), which REDUCE your cost base. Over a 15-year hold, cumulative AMIT adjustments can reduce cost base by 20–30% of the original purchase price.

The reform interacts: the FINAL adjusted cost base at disposal is what the split-treatment apportionment uses. So a long-held VAP unit with 20% cumulative AMIT reduction has a SMALLER cost base than the buy price → LARGER nominal gain → MORE gain to apportion across the reform line → MORE sensitivity to the timing math.

A worked example: $50k purchase 2020, 15 years of AMIT downward adjustments cumulating to $10k off cost base, sold 2035 for $95k. Old cost base ~$50k → $45k nominal gain. New cost base $40k → $55k nominal gain. The reform amplifies the difference — and the longer you hold a high-tax-deferred ETF, the more pronounced the effect.

Two CGT pathways accumulate independently with time

ETF investors face TWO time-dependent CGT streams that compound on different clocks:

  1. Distributed capital gains (annual, accruing inside the fund) — each year’s distributed gain is taxed under the rules applying when the FUND realised the underlying disposal. Distributions starting FY2027-28 may include both legacy and reform components, side-by-side on the same AMMA.
  2. Unit disposal (when you sell your ETF units) — your own buy-date and sell-date drive the bucket math, independent of what the fund did internally.

Both streams need separate apportionment math. Long-held DRP’d holdings will have ~15+ years of distributed-gain history layered on top of ~15+ years of parcel buy-dates by the time anyone unwinds in 2035–2040. Record-keeping discipline (CHESS statements, DRP confirmations, every AMMA in between) is the only thing that makes the math tractable when the sell button is finally pressed.

Bottom-line summary

  • 10+ year hold pre-reform, sold within 5 years after: legacy dominates, minimal reform impact.
  • Recent buy (2024–2026), 10–15 year hold: reform dominates, broad-equity and growth ETFs lose most.
  • Property/infrastructure ETFs with tax-deferred-heavy distributions: cost-base creep amplifies reform sensitivity.
  • Long-hold post-reform purchases (Bucket C, 15+ years): indexation can absorb most of the gain on low-yield ETFs.

Two CGT events to think about

Investors instinctively focus on the sale of their units. But ETFs and managed funds expose unitholders to a second CGT pathway that runs every year, quietly, regardless of whether you click “sell”.

EventWhen it triggersHow it reaches you
Distributed capital gainsFund manager realises a gain inside the fund (portfolio rebalance, index change, redemption pressure)Flows through as an attributed taxable amount on your AMIT-style annual tax statement, typically June. Currently eligible for the 50% discount at the unitholder level.
Disposal of fund unitsYou sell your VAS / VGS / Magellan / etc. unitsStandard CGT event A1 at the unitholder level. 50% discount currently if held >12 months.

The Budget 2026 reform applies to both pathways:

  • Capital gains accrued by the fund after 1 July 2027 flow through with the new rules — indexation + 30% minimum on the portion of the underlying gain that fell after that date.
  • Capital gain on disposal of fund units after 1 July 2027 follows the same three-bucket transition as direct shares — split treatment for units owned at 1 July 2027.

Investors who plan to hold an ETF for another decade can’t think of themselves as only exposed at the eventual sale date. Annual distributed capital gains are reform-eligible from FY2027–28 onward.

Three-bucket transition for unit disposal

The same A/B/C buckets from the master article apply when you sell ETF or managed-fund units:

BucketDescriptionRule for fund units
AUnits purchased AND sold before 1 July 2027No change. 50% discount applies as before.
BUnits owned before 1 July 2027 and sold afterSplit treatment. Pre-1 July 2027 portion uses 50% discount; post-1 July 2027 portion uses indexation + 30% minimum.
CUnits purchased after 1 July 2027 (and sold after)Wholly new rules across the full holding period.

How the Bucket B split works in the legislation. The enacted Act implements the split as a Subdiv 112-E “deemed sale”: every CGT asset you hold at 30 June 2027 is deemed disposed of just before 1 July 2027 and reacquired. The pre-1 July 2027 notional gain is calculated under the old law (50% discount preserved) and deferred until you actually sell; growth after 1 July 2027 is taxed under the new rules. The primary split method is market valuation at 1 July 2027 — for listed ETFs that is straightforward, the exchange closing price on 30 June 2027 — with a Minister-determined time-apportioning method available as a taxpayer election. The worked examples below use time-apportionment to illustrate the mechanics; for listed units the market-value split will usually be both easier and more accurate. Either way, keep a record of your fund’s unit price at 1 July 2027 (and your AMMA-adjusted cost base at that date) — that evidence anchors the split when you eventually sell.

ETF and managed-fund holdings have an extra complication: each parcel has its own acquisition date. A typical long-term VAS holding might consist of a 2015 purchase, monthly DRP reinvestments through 2024, a 2026 top-up, and a 2028 top-up. Every one of those parcels is on its own bucket. Reporting at sale requires you to identify the parcel and its acquisition date for each unit disposed of (under the parcel-selection method you elect — FIFO, LIFO, or specific identification).

ETF cost base adjustments (under the AMIT rules) — what changes

Most Australian-domiciled ETFs and managed funds operate under the Attribution Managed Investment Trust (AMIT) regime. In plain English: each year, your ETF tells you whether to adjust the price you paid for your units up or down for tax purposes. It’s printed on your annual tax statement (called an AMMA, or AMIT Member Annual Statement).

You don’t get to choose — the fund manager calculates the adjustment based on the gap between cash distributed and taxable income attributed. You just record it and apply it to your cost base.

Two directions of adjustment:

  • Downward — tax-deferred component (often called “return of capital” on your statement). When the fund distributes more cash than its attributed taxable income, the excess reduces your unit cost base. Common with property, infrastructure, and income-focused ETFs (VAP, MVA, DJRE).
  • Upward — over-distributed component. When the fund attributes more taxable income than it distributes in cash, the difference increases your cost base. Common with accumulating or low-yield equity strategies (VAS, A200 in low-yield years).

These mechanics are unchanged by the reform. What changes is how the final adjusted cost base at disposal flows into the apportionment.

Each year’s adjustments compound into the cost base running balance. At disposal, the adjusted cost base is what you use to compute the nominal gain. The reform then apportions that nominal gain into legacy and reform buckets by hold-period days.

Practically: if your VAS adjusted cost base is $86 per unit after 10 years of tax-deferred adjustments (versus an original $87 acquisition cost), it’s $86 that goes into the gain computation, and $86 that the bucket-B split treatment apportions across the pre/post 1 July 2027 boundary. Don’t try to apportion the cost-base adjustments themselves into reform vs legacy buckets — the apportionment lives at the gain level, not the cost-base level.

Where it gets messy — DRPs and AMIT adjustments: If you’ve reinvested distributions (DRP) AND your ETF has been adjusting your cost base each year (AMIT), you’ll have a stack of separate parcels with different buy-dates AND a cost base that’s drifted from what you originally paid. The split-rule apportionment uses your FINAL cost base — so update your records before you sell.

Keep every AMMA from acquisition through disposal — by 2030+, the legacy 10+ years of statements will be doing real work in your reform-era CGT computation.

Bucket B worked example — VAS ETF

Priya holds 1,000 units of VAS (Vanguard Australian Shares Index ETF), purchased on 12 February 2020.

ItemValue
Units1,000
Purchase price$87.20 / unit
Original cost base$87,200 + $19.95 brokerage = $87,219.95
AMIT cost-base adjustments over 10 years (net tax-deferred)−$1,200
Adjusted cost base at sale$86,019.95
Sale date5 March 2030
Sale price$128 / unit
Sale proceeds (after brokerage)$128,000 − $19.95 = $127,980.05
Nominal capital gain$41,960.10
Hold period~3,674 days (~10.06 years)
Pre-1 Jul 2027 days~2,696 days
Legacy share~73.4%

Step 1 — Apportion the nominal gain by hold-period days:

  • Legacy gain portion: $41,960.10 × 73.4% ≈ $30,798
  • Reform gain portion: $41,960.10 − $30,798 ≈ $11,162

Step 2 — Tax the legacy portion (50% discount, MTR 39% incl. Medicare):

  • Discounted legacy gain: $30,798 × 50% = $15,399
  • Legacy tax: $15,399 × 39% ≈ $6,006

Step 3 — Tax the reform portion (indexation, then 30% minimum):

Assume 2.5% per year CPI from 1 July 2027 to 5 March 2030 (~2.7 years) → cumulative CPI factor ≈ 1.070.

  • Indexation reduction: $11,162 × (1 − 1/1.070) ≈ $726
  • Real reform gain: $11,162 − $726 ≈ $10,436
  • Effective reform rate: max(MTR 39%, minimum 30%) = 39%
  • Reform tax: $10,436 × 39% ≈ $4,070

Step 4 — Total CGT:

ComponentTax
Legacy portion (Bucket B pre-2027)$6,006
Reform portion (Bucket B post-2027)$4,070
Total CGT under reform$10,076

Comparison vs old rules (single 50% discount across the whole gain):

  • $41,960.10 × 50% × 39% ≈ $8,182
  • Reform vs old: +$1,894 (about 23% more tax)

For a high-growth Australian equity ETF held across the 1 July 2027 boundary, expect the reform to add a meaningful single-digit-thousand-dollar tax bill per $40k of nominal gain — concentrated in the post-2027 share of the hold period, but reduced by whatever CPI has done in the interim.

You can plug your own VAS / VGS / VAP / NDQ / IVV parcels into the Capital Gains Tax Calculator — Bucket B apportionment with cost-base indexation is built in.

Bucket A worked example — selling before the boundary (James, VAS)

James bought 800 VAS units on 15 March 2022 at $89.50/unit and sells the lot on 25 June 2027 at $115/unit — five days before the 1 July 2027 boundary.

ItemValue
Units800
Purchase date15 March 2022
Purchase price$89.50 / unit
Original cost base (+ $9.95 brokerage)$71,609.95
Cumulative AMIT adjustments (net upward, low-yield years)+$320
Adjusted cost base$71,929.95
Sale date25 June 2027
Sale price$115 / unit
Sale proceeds (after $9.95 brokerage)$91,990.05
Nominal capital gain$20,060.10
Hold period~5.3 years (all pre-1 July 2027)

Because both the purchase and sale fall before 1 July 2027, this is a Bucket A transaction. The old rules apply in full:

  • Discounted gain: $20,060.10 × 50% = $10,030
  • At James’s MTR of 32.5% + 2% Medicare = 34.5%
  • CGT: $10,030 × 34.5% ≈ $3,460

Plain English: if you sell before 1 July 2027, nothing changes. The 50% discount still applies as it always did — Budget 2026 has no effect on transactions completed by the boundary. The same logic holds whether James sells one parcel or his entire holding, as long as everything trades before 1 July 2027.

Bucket C worked example — bought and sold under the new rules (Liam, NDQ)

Liam buys 500 units of BetaShares NDQ (Nasdaq 100 ETF, ASX-listed, Australian-domiciled) on 10 September 2028 at $42/unit, holds for ~6.5 years, and sells on 20 March 2035 at $74/unit. Both the purchase and sale fall after 1 July 2027 — this is a clean Bucket C example with no legacy portion.

ItemValue
Units500
Purchase date10 September 2028
Purchase price$42 / unit
Original cost base (+ $9.95 brokerage)$21,009.95
Cumulative AMIT adjustments (net upward, growth ETF)+$180
Adjusted cost base$21,189.95
Sale date20 March 2035
Sale price$74 / unit
Sale proceeds (after $9.95 brokerage)$36,990.05
Nominal capital gain$15,800.10
Hold period~6.5 years (all post-1 July 2027)

Step 1 — Apply indexation across the whole hold period.

Assume cumulative CPI of 18.5% across the 6.5-year hold → indexation factor 1.185.

  • Indexation reduction: $15,800.10 × (1 − 1/1.185) ≈ $2,466
  • Real reform gain: $15,800.10 − $2,466 ≈ $13,334

Step 2 — Apply the greater-of-MTR-or-30% rule.

  • Liam’s marginal rate: 37% + 2% Medicare = 39%
  • Effective rate: max(39%, 30%) = 39%
  • CGT: $13,334 × 39% ≈ $5,200

A point worth noting about NDQ. It tracks the Nasdaq 100 (all US stocks), but the unit Liam owns is in an Australian-domiciled trust managed by BetaShares in Sydney. Australia has no annual deemed-income regime for foreign portfolio holdings — the old Foreign Investment Fund (FIF) rules were repealed effective the 2010-11 income year — and in any case Liam holds an Australian trust unit, not the offshore assets directly. Distributions flow through under AMIT and the CGT reform applies normally on disposal.

Plain English: for someone buying a global-equity ETF entirely after the boundary, the calculation is simpler — no split, no apportionment, just indexation + 30% minimum across the whole gain. The 30% minimum becomes irrelevant when you’re already on a marginal rate above 30%. For lower-income investors (MTR 19% or 32.5%), the 30% floor is the binding constraint.

Foreign-domiciled ETF worked example (Rachel, US-listed VTI)

Rachel holds 50 units of US-listed VTI (Vanguard Total Stock Market ETF, NYSE Arca — not the ASX-listed VTS) bought directly through Interactive Brokers in August 2021 at US$220/unit. She sells in October 2029 at US$390/unit. AUD/USD is 0.68 at purchase and 0.66 at sale.

ItemValue
Units50
Purchase date5 August 2021
Purchase price (USD)US$220 / unit
Purchase price (AUD @ 0.68)$323.53 / unit
Original cost base (+ ~$15 brokerage AUD)$16,191.50
Sale date18 October 2029
Sale price (USD)US$390 / unit
Sale price (AUD @ 0.66)$590.91 / unit
Sale proceeds (after ~$15 brokerage AUD)$29,530.45
Nominal capital gain (AUD)$13,338.95
Hold period~8.2 years

No FIF — Australia repealed it. Rachel holds US-listed VTI directly, but Australia has had no Foreign Investment Fund regime since the 2010-11 income year. There is no annual deemed-income charge and no $50,000 threshold. A directly-held foreign ETF is taxed like any other CGT asset, across two timelines:

  • Dividends each year. VTI’s distributions are foreign income, assessable in the year received. US withholding tax (15% under the Australia–US tax treaty, provided Rachel lodged a W-8BEN) generates a Foreign Income Tax Offset (FITO) against her Australian tax, so the income isn’t taxed twice. There are no franking credits — that’s the real income-side difference from an ASX-domiciled ETF, not FIF.
  • Capital gain on disposal only. When Rachel sells in October 2029, CGT event A1 happens on the whole AUD gain — $13,338.95 — computed from the AUD cost base and AUD proceeds (the currency movement is already baked into those AUD figures, not taxed separately).

The gain is one CGT event, fully inside the reform. Purchase August 2021, sale October 2029 → Bucket B: ~5.9 of the ~8.2 years fall before 1 July 2027 (≈72% legacy) and ~2.3 years after (≈28% reform). The legacy ~72% of the $13,338.95 gain keeps the 50% discount; the reform ~28% runs through the new indexation + 30%-minimum rules — exactly the same machinery as an ASX-domiciled ETF. Nothing is taxed annually as you hold.

Plain English takeaway: A US-domiciled ETF (VTI, VOO, QQQ) held directly is taxed on its capital gain the same way as the ASX-domiciled equivalent (VTS, IVV, NDQ) — ordinary CGT on disposal, no annual deemed income. The genuine differences sit elsewhere:

  1. No franking credits on US ETF distributions, plus a W-8BEN and 15% US withholding to manage (offset by FITO).
  2. US estate tax can apply to US-situs assets — including US-domiciled ETFs — above US$60,000 for non-US-domiciliaries. This is the main reason many Australian investors prefer ASX-domiciled global ETFs.
  3. Currency and admin — USD distributions to convert each year.

None of these is FIF. If you hold US-listed ETFs and prefer to simplify, the ASX-listed equivalents (VTS, IVV) remove the US-situs estate-tax exposure and the franking/withholding admin — but the CGT treatment of the gain itself is unchanged. Talk to a tax agent if US estate-tax exposure or large foreign holdings are in play.

Distributed capital gains post-1 July 2027

When a fund realises a CGT event from its underlying holdings after 1 July 2027 (e.g. index rebalance, large redemption forcing a sale, takeover of an underlying company), the gain flows through to unitholders via AMIT attribution.

Under current rules, the discount is applied at the unitholder level — the fund attributes a gross capital gain; the unitholder applies the 50% discount themselves at year end. Under the reform:

  • The fund continues to attribute the gross capital gain.
  • The unitholder applies the new rules: indexation + 30% minimum tax on the real reform gain.
  • Effective rate is the greater of the unitholder’s marginal rate and 30%.

Statement labelling. From the 2027–28 income year onward, AMIT Member Annual Statements (AMMAs) will need to separately identify the legacy-portion (pre-1 July 2027) and reform-portion (post-1 July 2027) components of any attributed capital gain. Today’s AMMA format groups all discounted capital gain into a single line — expect the format to expand. Fund managers and platforms (Vanguard Personal Investor, Selfwealth, CommSec) will need to ship updated statement layouts before the first reform-era 30 June.

Apportionment within the fund. Where the underlying CGT event occurred is what governs apportionment for distributed gains — not when you bought the units. If the fund sells a holding it acquired in 2018 and the underlying gain crosses 1 July 2027, the same Bucket B apportionment applies at the fund level. The flow-through to you carries the apportioned components, not a single gross figure.

DRP creates many parcels

A 10-year DRP (Dividend Reinvestment Plan) on a fund like VAS, VAP, or VGS typically generates ~40 parcels (quarterly distributions). A 20-year DRP can generate ~80+. Every reinvestment is a separate parcel with its own:

  • Acquisition date
  • Acquisition price
  • Cost base
  • Hold-period bucket assignment

When you sell after 1 July 2027, you select parcels under your chosen method (FIFO, LIFO, or specific identification). Each selected parcel runs through its own Bucket A / B / C determination:

  • DRP parcels acquired before 1 July 2027 and sold after → Bucket B (split treatment)
  • DRP parcels acquired after 1 July 2027 → Bucket C (wholly new rules)
  • The original purchase parcel typically anchors the longest hold period and the largest legacy share

Investors who have not kept parcel-level records (acquisition date + price for each DRP reinvestment) should pull historical CHESS statements and broker DRP confirmations now. Reconstructing 15 years of DRP parcels in 2030 from broker statements is painful; reconstructing it from custodian-level records is worse.

Foreign-domiciled vs Australian-domiciled ETFs (general principles)

Many Australian investors hold ETFs that themselves hold foreign assets — VGS (developed-market shares ex-Australia), IVV (S&P 500), VTS (US total market), NDQ (Nasdaq-100), QUAL (global quality). A persistent myth is that “foreign” ETFs trigger a special annual tax. They don’t: Australia’s Foreign Investment Fund (FIF) rules were repealed effective the 2010-11 income year. There is no annual deemed-income charge and no $50,000 threshold for retail ETF investors. Both Australian-domiciled and foreign-domiciled ETFs are taxed under ordinary CGT on disposal, and the 2027 reform applies to that disposal gain the same way it applies to any share.

Australian-domiciled ETFs holding foreign assets (VGS, IVV via the iShares Australia structure, NDQ, etc.) operate as Australian unit trusts. Distributed income and capital gains flow through under AMIT; the fund manager handles the underlying foreign-asset compliance. The reform applies to these on disposal exactly as it would to a domestic-asset ETF: split treatment, reformed treatment of distributed capital gains.

Non-Australian-domiciled ETFs held directly (e.g. US-listed VTI, VOO, QQQ — distinct from the ASX-listed VTS) are taxed the same way on their capital gain — ordinary CGT on disposal, reform apportionment across the 1 July 2027 boundary. The differences are not FIF; they are:

  • No franking credits on distributions, and US dividends carry 15% US withholding (treaty rate with a W-8BEN), claimable as a Foreign Income Tax Offset.
  • US estate tax, which can apply to US-situs assets above US$60,000 for non-US-domiciliaries — the main reason many Australians prefer ASX-domiciled global ETFs.
  • Currency and admin — USD distributions to convert each year.

For most retail investors using Australian-domiciled global ETFs (the dominant Vanguard / BetaShares / iShares Australia products), none of this adds complexity beyond ordinary CGT. For those holding US-listed ETFs directly through IBKR or similar, the extra considerations are franking, withholding and US estate tax — not an annual deemed-income regime. Talk to a tax agent if large foreign or US-situs holdings are in play.

Tax-deferred distributions and the “iceberg” effect

Property and infrastructure ETFs (VAP, MVA, DJRE, GLPR, SLF) typically distribute large tax-deferred components — often 30–50% of distributed yield is return of capital, not assessable income. Over a long hold, those tax-deferred amounts compound downward into the cost base. After 15+ years, the adjusted cost base can sit well below the original purchase price — sometimes approaching zero or negative.

Under the current 50% discount regime, a “negative cost base” outcome on disposal still attracts the discount, cushioning the tax on the inflated nominal gain. Under the reform, that cushion narrows materially:

  • The reform-portion gain is taxed at minimum 30% with only the (modest) post-2027 CPI indexation to offset it.
  • A reform-era unitholder with $50,000 of nominal gain inflated by 20 years of tax-deferred adjustments faces ~30% on the real reform portion regardless of marginal rate — versus 15–24% under the old 50% discount.

Long-hold, tax-deferred-heavy property and infrastructure ETFs become less tax-efficient post-2027 relative to plain Australian equity ETFs. The yield-vs-growth trade-off doesn’t change, but the after-tax outcome does — particularly for high-MTR investors planning to hold for another decade.

Loss harvesting and tax-aware ETFs

Tax-aware ETFs (those that select parcels at distribution time to minimise distributed capital gains) and active tax-loss-harvesting strategies remain useful post-reform — the discount that frames realised gain has narrowed, so the tax shielding from harvested losses grows in relative value.

One-off opportunity in FY2026–27: capital losses harvested before 30 June 2027 can offset legacy-discount-era capital gains. Carry-forward losses applied against post-2027 gains will instead offset reform-era gains, where the effective tax rate may be higher but the indexation cushion reduces the gross amount available to offset. Front-loading harvest activity into FY2026–27 captures the better-of-both outcome.

See the CGT Harvest Calculator for a ranking of loss candidates by potential tax saving.

Decision points for ETF investors

Should you sell long-held ETFs before 1 July 2027?

No — not for tax reasons alone. The legacy 50% discount on the pre-2027 portion of any gain is preserved under Bucket B regardless of when you sell. Triggering a sale today crystallises tax today and forfeits the deferral benefit (re-invested at-tax-paid versus continuing to compound pre-tax). Only sell if the underlying investment decision makes sense without the tax angle.

Should you switch to an accumulating fund?

Accumulating funds (those that reinvest income internally rather than distributing) and distributing funds are subject to the same tax regime — AMIT applies to both, and the reform applies to both. There is no tax-driven reason to switch between structures.

Should you stop DRP and take cash distributions?

DRP creates more parcels and more reporting overhead, but each parcel still benefits from its own bucket assignment — long-DRP parcels still attract their share of legacy treatment. The decision to stop DRP should rest on portfolio-construction reasons (rebalancing flexibility, withdrawal needs), not tax timing.

Should you favour individual shares over ETFs?

No structural advantage either way. Direct shares get the same Bucket A/B/C treatment as ETF units. ETFs add the distributed-capital-gain layer; direct shares don’t. ETF managers do parcel selection on your behalf at the fund level — for most investors, that’s a feature, not a bug.

Calculators

Sources

  • Treasury Laws Amendment (Tax Reform No. 1) Act 2026 (No. 49 of 2026) and Income Tax Rates Amendment (Tax Reform No. 1) Act 2026 (No. 50 of 2026) — royal assent 26 June 2026 (legislation.gov.au).
  • APH bill homepage — Treasury Laws Amendment (Tax Reform No. 1) Bill 2026 — passage history and Senate amendments.
  • Treasury Budget Paper No. 2, Tax Reform — Boosting Home Ownership (12 May 2026), p.21 — original announcement.
  • Treasury fact sheet, Negative Gearing and Capital Gains Tax Reform (12 May 2026).
  • AMIT regime overview (ATO website) — Attribution Managed Investment Trusts — flow-through attribution, cost-base adjustment mechanics, AMMA reporting framework.

Primary sources

Where to go next