Section 100A of the Income Tax Assessment Act 1936 (ITAA 1936) is an anti-avoidance provision that can apply where a trust beneficiary's present entitlement arises from a reimbursement agreement — that is, an arrangement where the economic benefit of the distribution does not actually flow to the beneficiary in a way consistent with ordinary dealing. If Section 100A applies, the trustee (not the beneficiary) is assessed on the distributed income at the top marginal tax rate of 45%, plus Medicare Levy. The ATO released Practical Compliance Guideline PCG 2022/2 in 2022, which sets out the ATO's risk framework and indicates the types of arrangements it is likely to scrutinise. ChangeGPS Section 100A implements PCG 2022/2 to help accountants identify which distributions are at risk before the trust's income year-end resolutions are finalised.