This article walks you through the complete Section 100A workflow in ChangeGPS — from entering trust and beneficiary details through to generating and delivering the risk assessment report. The Section 100A app uses a five-step wizard covering client setup, distribution scenarios, risk assessment, document content, and final review.
Before you begin
Before starting a Section 100A assessment, make sure you have the following information available:
The trust name, trustee name(s), and ACN (if applicable)
The names and relationships of all beneficiaries (including whether they are associates of each other or of the trustee)
The proposed distribution amounts or percentages for each beneficiary
Each beneficiary's estimated taxable income for the year (for tax calculation purposes)
Details of any arrangement between the trust and a beneficiary regarding how the entitlement will actually be dealt with (for example, whether it will be paid in cash, left as a loan, offset against another arrangement, or applied to a related company)
Whether there are any related private companies involved in the distribution arrangement
Step-by-step guide
Step 1 — Client & Entity Details
(Click on Image to enlarge)
Navigate to the Section 100A app. Please go to Access > Apps > ChangeGPS S100A. Select + New Assessment.
Select Import from CIM to search for the trust in the Client Import Manager, or enter the trust details manually.
Enter the Trust Name and ACN (if the trustee is a company).
Enter the Trustee name and type.
In the Beneficiaries table, select Add Beneficiary and enter each beneficiary's name and relationship to the trust (for example, Individual Beneficiary, Corporate Beneficiary, or Related Trust).
Use the drag-and-drop handles to reorder beneficiaries if needed — the order affects how they appear in the generated report.
Select Next to proceed to Step 2.
Step 2 — Tax Configuration
Enter the Base Tax Information shared across all scenarios — this includes the trust's net income and franking credit rate attached to the distribution.
In the Scenarios tabs, the default scenario is created automatically. To add a comparison scenario, select + Add Scenario and give it a descriptive name (for example, "Equal Split" or "Company Distribution").
For each scenario, enter the distribution amount or percentage for each beneficiary. Toggle between Dollar and Percentage input modes using the input type toggle.
The Tax Results Preview shows the estimated tax position for each beneficiary in real time as you enter distribution values, including the effect of any franking credits attributed to the distribution.
Mark your preferred scenario as Recommended — this scenario will be featured in the generated advice report.
Select Next to proceed to Step 3.
Step 3 — Risk Assessment
Step 3 is the core of the Section 100A assessment. You answer the PCG 2022/2 decision tree for each beneficiary, and the app calculates their risk zone automatically.
Select the first beneficiary from the beneficiary list on the left.
Work through the PCG 2022/2 Questionnaire. The questions are divided into sections:
Is there a reimbursement agreement? — Establishes whether Section 100A can apply at all
Ordinary dealing test — Assesses whether the arrangement is consistent with ordinary family or commercial dealing
Specific risk factors — Evaluates factors that increase or decrease risk under PCG 2022/2
The Risk Zone for that beneficiary is calculated automatically after each answer and displayed as a coloured badge:
GREEN — Low risk. The ATO is unlikely to apply Section 100A resources to this arrangement.
AMBER — Medium risk. The arrangement warrants review. Consider restructuring before finalising distributions.
RED — High risk. Specialist advice is recommended before proceeding with this distribution.
NO_RISK — No reimbursement arrangement has been identified. Section 100A does not apply.
WHITE — Out of scope. The beneficiary is outside the scope of PCG 2022/2 (for example, an exempt entity).
Review the Green Zone Suggestions panel, which identifies what changes to the arrangement would bring an AMBER or RED beneficiary into the GREEN zone.
If your professional judgement differs from the calculated risk zone, select Override and enter an explanation. The override is recorded in the risk history audit trail.
Repeat for each beneficiary in the assessment.
Select Next to proceed to Step 4.
Step 4 — Document Content
Review the pre-populated content sections for the advice report — these are generated based on the risk assessment results and distribution details entered in the earlier steps.
Edit any sections as needed to reflect your professional advice and the specific circumstances of the trust.
Select Next to proceed to Step 5.
Step 5 — Review & Send
Review the completed Section 100A assessment report in the preview panel. The report includes:
Trust and beneficiary details
Distribution scenario (recommended scenario)
Risk zone assessment per beneficiary with supporting reasoning
Recommendations for any AMBER or RED beneficiaries
Use the actions sidebar to export or deliver the report:
Export PDF — Download the report as a PDF
Export Word — Download as a Word document (.docx)
Add Pages — Merge additional documents into the report using the Collate widget
Send Email — Email the report directly to your client from within the module
Tips and best practices
Run the assessment before trust resolutions are signed. Section 100A is most useful when you can still adjust the distribution approach if a HIGH or AMBER risk is identified. Running the assessment before finalising resolutions gives you the opportunity to restructure if needed.
Use multiple scenarios to find the lowest-risk distribution. The Tax Configuration step allows you to model different distribution approaches and compare both the tax outcomes and the risk profile before deciding which distribution to recommend.
Document your reasoning for GREEN zone conclusions. Even where the calculated risk zone is GREEN, adding notes in the questionnaire responses provides a contemporaneous record of your analysis that can be used if the ATO queries the arrangement in future.
Review Green Zone Suggestions for AMBER beneficiaries. The module identifies what changes would move an AMBER beneficiary to GREEN. These suggestions often point to practical adjustments such as ensuring the beneficiary actually receives the distribution in cash rather than leaving it as a loan.
Use the override carefully. The risk zone override is for cases where your professional judgement materially differs from the automated result — for example, where you have additional legal advice confirming the arrangement is not a reimbursement agreement. Always enter a clear explanation when overriding.
Common issues
A beneficiary is showing as AMBER but I believe the arrangement is GREEN. Review each answer in the PCG 2022/2 questionnaire to identify which factor is driving the AMBER classification. The Green Zone Suggestions panel will identify what would need to change. If you have considered all factors and your professional judgement is that the arrangement is within the GREEN zone, use the Override button to record your conclusion and reasoning. The override is logged in the risk history.
The tax calculation results appear incorrect for a beneficiary. Check that the base tax information in Step 2 is correct — particularly the trust net income and franking credits. Also confirm that the beneficiary's individual taxable income has been entered correctly, as this affects the marginal tax rate applied to the distribution. The real-time calculations update as you change values, so any correction will be reflected immediately.
I cannot see the Green Zone Suggestions for a RED beneficiary. Green Zone Suggestions are generated for AMBER and some RED beneficiaries based on the specific risk factors identified in the questionnaire. For RED beneficiaries where the fundamental arrangement involves features that inherently attract Section 100A risk (for example, a distribution to a related company with no genuine commercial purpose), the suggestion may be that the arrangement needs to be substantially restructured or that specialist legal advice is required.
Need help?
If you are stuck or have questions about a Section 100A risk assessment, reach out through the chat widget or contact your account manager.