
As your business grows and your investment portfolio expands, a common question arises in our boardrooms at Rider Accountants: “How do I stop paying 47% tax on my hard-earned profits?”
Most business owners are familiar with the “Family Trust.” Some have even graduated to using a Bucket Company. But for high-net-worth families, there is a more sophisticated level—the “Ultra” Golden Structure.
In this post, we break down how this dual-trust model works, why it’s a game-changer for capital gains, and what it actually costs to run.
The “Ultra” version moves away from a single entity and creates a “Family Ecosystem” consisting of:
The Trading/Family Trust: This is your engine room. It runs your business or receives your primary income.
The Corporate Trustee: A Pty Ltd company that manages the trust. This provides a “corporate veil” to protect your personal family home from business risks.
The Bucket Company (Corporate Beneficiary): Instead of paying 47% tax as an individual, you distribute profits to this company and cap the tax at 25% or 30%.
The Investment Trust: This is the “Ultra” addition. This separate trust holds your long-term assets (property and shares) to ensure you don’t lose your 50% Capital Gains Tax (CGT) discount.
The genius of the Ultra structure lies in how these entities interact.
When your Bucket Company accumulates after-tax cash, you don’t want it sitting idle. However, if the company buys a property directly, it cannot claim the 50% CGT discount when it sells.
The Fix: The Bucket Company lends the cash to the Investment Trust via a formal Division 7A Loan Agreement. The Investment Trust then buys the asset.
The Benefit: You used “low-taxed” company money to fund the purchase.
The Win: Because a Trust owns the asset, you keep the 50% CGT discount upon sale.
The Loop: The interest paid on the loan is a tax deduction for the Investment Trust and income for the Company. You are effectively “recycling” wealth within your own family group.
Sophistication requires compliance. Because the ATO monitors inter-entity loans (Div 7A) closely, this structure requires diligent management.
Expect a one-off investment of $4,000 to $10,000+. This covers the registration of multiple companies with ASIC, drafting specialized Trust Deeds, and creating the legal loan frameworks required to stay ATO-compliant.
To keep the “Ultra” structure running, you are looking at:
ASIC Fees: ~$329 per company.
Software Fees: Multiple Xero/MYOB files for separate tracking.
Accounting & Tax: Budget between $7,500 and $15,000+ annually for the preparation of multiple tax returns, financial statements, and Division 7A management.
At Rider Accountants, we generally find the “Ultra” structure becomes mathematically superior once your annual taxable profit consistently exceeds $250,000 – $300,000.
If your profits are lower, the accounting fees may outweigh the tax savings. However, if you are looking to build a multi-generational property or share portfolio, the asset protection and CGT benefits are often priceless.
Don’t wait until June 30th to find out you’ve overpaid the taxman. Building a structure like this requires careful planning and a deep understanding of your long-term goals.
Take the Review to See if you Would Qualify for a Golden Tax Planning Strategy