The Wait is Over… or is it? The 30% Minimum Tax Exposure Draft Legislation Provides Answers, But Questions Remain

On 3 September 2026, the Treasury released the much-anticipated exposure draft legislation and explanatory materials implementing the core components of the 30% minimum tax on discretionary trusts, which was announced as part of the 2026-27 Budget (Exposure Draft). If nothing else, the Exposure Draft provides more certainty for taxpayers who have been grappling with the question of whether to restructure. However, it is clear that no single solution has emerged for taxpayers affected by the proposed changes.