PCG 2022/2 sorts section 100A arrangements into white, green and red zones. There is no blue zone: that was proposed in the draft, PCG 2022/D1, and did not survive into the final guideline. This tool classifies the facts you supply against the green and red zones, works out Division 6 shares, and calculates a section 99B amount on a foreign trust distribution.
Section 100A can treat a trust distribution as a reimbursement agreement and tax it at the top rate instead of the beneficiary's own rate. The ATO's finalised guideline, PCG 2022/2, sorts arrangements into risk zones. It is easy to mix this up with the earlier draft: PCG 2022/D1 proposed a blue zone, but the final PCG 2022/2 has only white, green and red. There is no blue zone.
This tool classifies the facts you supply against the green and red zones. The white zone, for income years ending before 1 July 2014, is out of scope because the tool does not take an income year. It also works out each beneficiary's proportionate share of trust income under Division 6, following the High Court's decision in Bamford, and the assessable amount on a foreign trust distribution under section 99B.
Where the tool does not implement a rule, such as streamed capital gains and franked dividends under the Division 6E carve-out, it refuses the input rather than returning a number it cannot stand behind.
Nothing this engine produces is tax, legal or financial advice, an assessment or a determination. Outputs are review aids: confirm every allocation, zone and exemption against the current law, the trust deed and the entity's facts before acting, and leave lodgement decisions with a registered practitioner. Where the model does not implement a rule it refuses the input rather than returning a number it cannot stand behind.
No. The blue zone appeared only in the draft, PCG 2022/D1. The finalised PCG 2022/2 has white, green and red zones only.
It covers arrangements in income years ending before 1 July 2014. This tool does not take an income year, so the white zone is out of scope here.
Proportionately, following the High Court's decision in Bamford: a beneficiary's share of trust income sets the proportion of the trust's taxable income assessed to them.
Anything it does not implement, including streamed capital gains and franked dividends under the Division 6E carve-out. It refuses the input rather than returning a number it cannot stand behind.