Section 100A is a ChangeGPS app that helps accountants assess whether trust distributions are at risk of triggering the Section 100A anti-avoidance provisions under the Income Tax Assessment Act 1936 (ITAA 1936). The app implements the ATO's Practical Compliance Guideline PCG 2022/2, which sets out the ATO's compliance approach to reimbursement agreements involving trust distributions. It guides you through a structured five-step assessment that determines whether each beneficiary's distribution falls into the GREEN (low risk), AMBER (medium risk), or RED (high risk) zone under PCG 2022/2.
Section 100A is available in Australia.
What Section 100A does
The Section 100A app conducts a structured risk assessment for each beneficiary of a trust distribution, applying the ATO's decision tree from PCG 2022/2 to determine the risk zone for each arrangement.
The app supports multiple distribution scenarios per assessment, allowing you to model and compare the risk profile of different distribution approaches before finalising the trust's resolutions.
Real-time tax calculations show the tax position for each beneficiary across all scenarios, with franking credit calculations included.
The app determines a GREEN, AMBER, RED, or NO_RISK zone for each beneficiary based on the answers to the PCG 2022/2 questionnaire, with a full risk history and the ability to override the calculated zone with an explanation.
Section 100A generates a professional advice report that documents the assessment, risk zones, and recommendations for each beneficiary.
Who should use Section 100A
Section 100A is designed for accountants and tax advisors who manage discretionary trust clients and need to assess whether the ATO is likely to challenge the trust's distribution arrangements as a reimbursement agreement under Section 100A. It is relevant for any trust that distributes income to beneficiaries who are associated parties — particularly where there is a related private company or where a high-income beneficiary's entitlement is not matched by an economic benefit.
The app is particularly valuable when used annually as part of the trust distribution process, before resolutions are signed.
Key features
PCG 2022/2 decision tree — A 40+ question assessment implementing the ATO's compliance guideline to determine risk zones for each beneficiary arrangement.
Five risk zones — WHITE (out of scope), GREEN (low risk, compliant with PCG 2022/2), AMBER (medium risk, review recommended), RED (high risk, specialist advice required), and NO_RISK (no reimbursement arrangement identified).
Multiple distribution scenarios — Model and compare different distribution approaches across scenarios before finalising, with real-time tax calculations for each.
Per-beneficiary risk assessment — Each beneficiary is assessed individually, with their own risk zone and supporting explanation.
Risk zone override — Override the calculated risk zone with an explanation and audit trail, where professional judgement differs from the automated result.
Green Zone suggestions — The app identifies what changes to the distribution arrangement would bring a beneficiary's arrangement into the GREEN zone.
Risk history — Track how the risk assessment has changed over time for the same trust and beneficiary.
Franking credits — Calculates franking credits attributed to each beneficiary as part of the distribution scenario.
CIM client import — Import trust and beneficiary details from the Client Import Manager (CIM).
Collate integration — Merge additional documents into the advice report before downloading.
How Section 100A fits into ChangeGPS
Tax Plan — Section 100A risk assessment results can inform the trust distribution strategy modelled in Tax Plan. A RED zone finding should prompt a review of the distribution approach before finalising the Tax Plan scenarios.
Client Import Manager (CIM) — Trust and beneficiary details can be imported from CIM to pre-fill Step 1.
Getting started
Navigate to the Section 100A app from the ChangeGPS dashboard and select New Assessment.
In Step 1 — Client & Entity Details, enter the trust name, trustee details, and add all beneficiaries with their relationships to the trust and to each other.
In Step 2 — Tax Configuration, enter the base tax information and configure distribution amounts per beneficiary across one or more scenarios.
In Step 3 — Risk Assessment, answer the PCG 2022/2 questionnaire for each beneficiary to determine their risk zone.
In Step 4 — Document Content, review and customise the content of the advice report.
In Step 5 — Review & Send, preview, export, and deliver the completed assessment report.
Need help?
If you have questions about Section 100A or need assistance with a specific trust distribution scenario, reach out to our support team through the chat widget or contact your account manager.