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MGS Products — Hybrid Trust Solutions

MGS Hybrid
Discretionary Trust

All the flexibility of a discretionary trust — with the ability to issue Special Units conferring fixed income entitlements when required. One deed. Two modes. ATO-compliant. Drafted by MGS in direct consultation with the Commissioner.

At a glance
Discretionary mode
Full trustee discretion over income and capital when no units are on issue
Unit mode
Issue Special Units to confer fixed income entitlements on nominated holders
ATO-compliant
Deed does not contain any of the features identified as offensive in TA 2008/3
Private Binding Ruling
MGS holds a PBR confirming the deductibility of interest on borrowings to acquire units
Discretionary Foundation
Operates as a full discretionary trust — income and capital distributed at absolute trustee discretion
Special Unit Issue
Issue Special Income Units, Special Capital Units or other bespoke units with defined entitlements when needed
Gearing & Deductibility
Unit holders may borrow to acquire units — MGS holds a Private Binding Ruling confirming interest deductibility
ATO-Compliant
Drafted in consultation with the ATO — contains none of the TA 2008/3 features identified as offensive by the Commissioner
Important — Caution Required

Following Taxpayer Alert TA 2008/3, a great deal of caution needs to be exercised in establishing and operating Hybrid Discretionary Trusts. MGS has worked directly with the ATO on this issue. Our deed does not contain any of the features the Commissioner has described as offensive. If you have an existing hybrid trust from another provider, consider having it reviewed.

Overview

Discretionary trust flexibility — with unit trust capability


An MGS Hybrid Discretionary Trust has all the features of an MGS Discretionary Trust — a Settlor, Trustee, Appointor, Controller (optional), Principal Beneficiary, and broad beneficiary class — but additionally vests the Trustee with the power to issue Special Units.

The Special Units may be called Special Income Units, Special Capital Units, or any other distinctive name the Trustee determines. The income and capital rights attaching to each class of unit are described in the Certificate of Units issued on creation. In this way, the trust can operate simultaneously as a discretionary trust (for general beneficiaries) and as a fixed-entitlement structure (for unit holders), or alternate between the two modes as circumstances require.

There do not have to be any units on issue at the time the trust is created — or ever. Where units are issued, they must be issued and redeemed at amounts reflecting the market value of the underlying trust assets, to protect unit holders' interest deductibility and to avoid the CGT market-value substitution rules.

The key advantage: A Hybrid Discretionary Trust can operate as a routine unit trust — vesting unit holders with fixed entitlements — and as a routine discretionary trust — allowing income and capital distributions at trustee discretion — either separately or simultaneously. This dual capability makes it an extremely flexible vehicle for estate planning, asset protection, and tax efficiency.
Key Features at a Glance
  • All features of an MGS Discretionary Trust — full beneficiary class and trustee discretion
  • Power to issue Special Units — Special Income Units, Special Capital Units, or custom classes
  • Unit entitlements defined in Certificate of Units — customised per unit class
  • No units required at establishment — or ever — structure remains discretionary if preferred
  • Units issued and redeemed at market value — protects interest deductibility
  • Unit holders entitled to ordinary income and realised capital gains proportionally
  • Entitlement cannot be defeated — including by way of accumulation
  • Deed does not contain any feature identified as offensive in TA 2008/3
  • MGS holds a Private Binding Ruling confirming interest deductibility
  • ATO-compliant amendment available for pre-2011 MGS hybrid trusts
How It Works

Two modes — one deed

The trust can operate in discretionary mode, unit mode, or both simultaneously. The Trustee switches between modes by issuing or redeeming Special Units.

Mode 1 — No units on issue
Discretionary Mode
  • Trustee distributes income and capital to any beneficiary in any proportion
  • Income may be accumulated at the Trustee's discretion
  • Capital distributions at absolute trustee discretion before the Vesting Day
  • Full income streaming — CGT discount, franking credits and foreign income
  • Appointor controls trustee appointment and removal
  • Broad beneficiary class — Primary Beneficiary, family and related entities
Operates identically to an MGS Discretionary Trust. Activates whenever there are no Special Units on issue — including after full redemption of a prior unit issuance.
Issue /
Redeem
Units
Mode 2 — Units on issue
Unit Mode
  • Special Units confer fixed income entitlements on unit holders
  • Unit holder receives proportional share of income reasonably attributable to their investment
  • Entitlement includes ordinary income and realised capital gains
  • Entitlement cannot be defeated by trustee — including by accumulation
  • Units redeemed at market value — protecting interest deductibility
  • Remaining income and capital distributed at trustee discretion to general beneficiaries
Activates on issuance of first Special Unit. Multiple unit classes may exist simultaneously. Unit holders and discretionary beneficiaries may receive distributions concurrently.
The Parties

Understanding the key roles

The MGS Hybrid Discretionary Trust has the same party structure as a discretionary trust — plus the addition of Special Unit Holders when units are issued.

Settlor

Pays the Settlement Sum to establish the trust. Must not be a beneficiary — to avoid adverse tax consequences. Typically an unrelated person (a staff member, friend or relative of the adviser) who takes no further role in trust affairs.

Trustee

Holds legal title to the Trust Fund and administers the trust. In a hybrid trust the Trustee has the additional power to issue Special Units. Typically a corporate trustee. Owes fiduciary duties to all beneficiaries and unit holders. Liable for trust debts with a right of indemnity from trust assets.

Appointor

Holds the power to remove and replace the Trustee at any time by written notice. The Appointor exercises effective control over the trust — the Trust Fund is accountable in Family Law Act property settlement matters. More than one Appointor may act jointly.

Primary Beneficiary & Beneficiaries

The Primary Beneficiary anchors the general beneficiary class — their spouse, children, parents, grandparents and other relatives are automatically included. No beneficiary has a vested interest in the Trust Fund. Trustee distributes income and capital at absolute discretion. Primary Beneficiary is the default taker of undistributed income.

Controller (optional)

Where named, provides consent for certain trustee actions — such as appointing additional beneficiaries, varying the deed, and determining an earlier Vesting Date. The Family Court is likely to find that a Controller has control of the trust for property settlement purposes.

Special Unit Holders

Persons or entities issued with Special Units. Each Special Unit confers a fixed income entitlement as described in the Certificate of Units — typically the proportional share of trust income reasonably attributable to the unit holder's investment. Unit holders must acquire and redeem units at market value. Their entitlement cannot be defeated, even by trustee accumulation.

Special Units

How Special Units work


Special Units are the distinguishing feature of a hybrid discretionary trust. The Trustee may issue them at any time — at $1.00 each (recommended for simplicity) or at another denomination — provided the total value of units issued reflects the market value of the unit holder's proportional interest in the underlying trust assets.

For example: a trust with assets of $500,000 that issues 250,000 Special Units at $1 each would give those units a 50% interest in the trust. Those units would then be entitled to 50% of the income of the trust reasonably attributable to the investment — both ordinary income and realised capital gains.

The rights attached to each class of unit are set out in the Certificate of Units. The Trustee has absolute discretion in determining those rights — subject to the ATO's requirements to protect interest deductibility.

Redemption at market value is essential. Special Units that have been redeemed entitle the former holder to receive the market value of the units at redemption. Adopting any other formula — cost price, cost plus CPI, or less than market value — will seriously jeopardise the deductibility of interest on any funds borrowed by the unit holder to acquire those units. Always redeem at market value.

Apart from their redemption entitlement, holders of Special Units do not have an entitlement to any part of the corpus (capital) of the Trust Fund — unless the Certificate of Units specifically provides for capital entitlements (as in the case of Special Capital Units).

Example — $500,000 Trust
Units issued
250,000
at $1.00 each
Unit holder's share
50%
of trust income
Units = $250,000 ÷ $500,000 trust assets = 50% proportional interest. The unit holder is entitled to 50% of the net income of the trust reasonably attributable to their investment — both ordinary income and realised capital gains. The remaining 50% is distributed at the Trustee's discretion to general beneficiaries.
ATO Requirements for Interest Deductibility

To be entitled to deductions for interest expenses on borrowings to acquire units, unit holders must:

  • Essentially be in the same position they would be in if holding the underlying asset directly
  • Be entitled to both the ordinary income of the trust and its realised capital gains
  • Have their units redeemed at amounts reflecting the market value of the underlying asset
MGS hybrid trusts satisfy all three requirements. The MGS Private Binding Ruling confirms this position.
ATO Compliance — TA 2008/3

The Commissioner's concerns — and why the MGS deed is safe


In Taxpayer Alert TA 2008/3, the Commissioner identified a number of features of poorly drafted hybrid discretionary trusts that jeopardise the deductibility of interest on unit holder borrowings. These features were found in trusts where providers made overly aggressive claims — including that capital gains could be streamed away from unit holders, that units could be redeemed below market value, and that no adverse legislation could ever affect the deed.

MGS has been in communication with the ATO for years concerning hybrid trusts and worked directly with the ATO to produce a compliant form of deed. The MGS deed does not contain any of the features that the Commissioner has described as offensive. MGS also holds a Private Binding Ruling on the deductibility of interest confirming the position for MGS hybrid trust unit holders.

If you have a pre-2011 MGS Hybrid Trust: The deed should be amended to reflect the features settled with the ATO in 2011. MGS provides an Amendment Kit covering the Deed of Variation, the Private Binding Ruling, and a full guide to using the trust after amendment. See Hybrid Trust Amendment Kit.
If you have a hybrid trust from another provider: Your deed should be checked and, if necessary, amended to bring it in line with what the ATO will accept. The trust deed, application for units, and unit certificates should all be reviewed. Email MGS for a free review.
Features the Commissioner finds offensive (TA 2008/3)
  • An ability to defeat a unit holder's entitlement to receive fixed proportions of trust income and capital gains
  • A unit holder not being entitled to receive distributions of the trust's capital gains at all
  • Interests or entitlements being conferred upon associates of a unit holder for less-than-market-value consideration
  • A unit holder's entitlement to ordinary income being less than what it should be — meaning they borrowed to fund income to which other beneficiaries are entitled
  • A unit holder only being entitled to receive distributions of capital gains (not ordinary income)
  • A unit holder's interest in the trust ending before the cost of their investment has been recouped
  • A unit holder redeeming their units at their purchase price or less than market value
  • Units being purchased at an amount less than their market value
MGS deed: None of the above features appear in the MGS Hybrid Discretionary Trust deed. The MGS deed was drafted specifically to address the Commissioner's concerns and is supported by a Private Binding Ruling confirming interest deductibility for compliant unit holders.
Existing Hybrid Trusts

Do you have an existing hybrid trust?

Whether it was established through MGS or another provider, your hybrid trust deed should be reviewed for TA 2008/3 compliance.

Pre-2011 MGS Hybrid Trust

If your MGS Hybrid Trust was established before 2011, the deed should be amended so it is in line with what the ATO accepts. Some features which formed part of the ruling were only settled in 2011. MGS provides a full Amendment Kit including the Deed of Variation, the Private Binding Ruling and Reasons for Decision, and a guide to using the trust after amendment.

Property Investor Trust

The Property Investor Trust is a hybrid discretionary trust developed by Chan & Naylor. Many of its clauses and features would not be acceptable to the ATO, and interest deductibility for geared unit holders would be at risk. Contact MGS for an amendment to bring the deed in line with what the ATO accepts.

Another Provider's Hybrid Trust

If your hybrid discretionary trust was established through any other provider, the deed should be checked and — if necessary — amended to bring it in line with what the ATO accepts. The trust deed, application for units, and unit certificates should all be reviewed.

Questions & Answers

Frequently asked questions


Common questions about the MGS Hybrid Discretionary Trust. Contact our team for matters specific to your client's circumstances.

A hybrid discretionary trust is a discretionary trust that has been enhanced with the power to issue units. It has no statutory or judicial definition — its features vary between providers. An MGS Hybrid Discretionary Trust has all the features of an MGS Discretionary Trust plus the Trustee's power to issue Special Units (Special Income Units, Special Capital Units, or other classes). It can operate as a discretionary trust alone, as a unit trust alone, or as both simultaneously — making it one of the most flexible trust structures available in Australia.
No. There do not have to be any units of any description on issue at the time of creation of the hybrid discretionary trust — nor, indeed, at any other time. The trust can operate purely as a discretionary trust indefinitely. The Trustee may issue Special Units at any future time when the circumstances make it appropriate — for example when a family member wishes to gear into the trust's assets, or when a lender or co-investor requires fixed entitlements.
Special Units must be issued and redeemed at amounts reflecting the market value of the unit holder's proportional interest in the underlying trust assets. A denomination of $1.00 per unit is recommended for simplicity. The total number of units issued multiplied by the issue price must reflect the market value of the new unit holder's proportional interest — to do otherwise risks the Commissioner substituting market value under the CGT market-value substitution rules. On redemption, any formula other than market value — including cost price, cost plus CPI, or any amount below market value — will seriously jeopardise the deductibility of interest on any borrowings used to acquire those units.
Yes — provided the unit holder satisfies the ATO's three requirements: (1) the unit holder is essentially in the same position they would be in if holding the underlying asset directly; (2) the unit holder is entitled to both the ordinary income and the realised capital gains of the trust; and (3) units are redeemed at market value. The MGS deed satisfies all three requirements. MGS also holds a Private Binding Ruling from the ATO confirming interest deductibility for compliant MGS hybrid trust unit holders. The refinancing principle from FC of T v Roberts & Smith 92 ATC 4380 also applies.
No — and this is one of the areas where some other providers' deeds are non-compliant. Streaming capital gains away from unit holders is possible from a trust law perspective, but it seriously jeopardises the deductibility of interest on the unit holder's borrowings. Under the proportionate theory (PS LA 2005/1), unit holders entitled to trust income will also receive a distribution of an appropriate proportion of realised capital gains. The MGS deed specifically provides that unit holders are entitled to that proportion of the net income of the trust (ordinary and statutory, including realised capital gains) reasonably attributable to their investment. This entitlement cannot be defeated — including by accumulation.
Generally no — and claims by some providers that hybrid trusts qualify for land tax concessions should be treated with caution. Land tax concessional rates typically require that all interests in the income and capital of the trust are vested and indefeasible — which cannot be said of a hybrid discretionary trust, which retains discretionary features. Where land is held in the trust, specific State land tax advice is essential. Do not rely on aggressive claims by providers that land tax concessions are available — the ATO and State revenue authorities have increasingly scrutinised such claims.
The Commissioner also raised concerns regarding distributions from hybrid discretionary trusts to complying superannuation funds in Taxpayer Alert TA 2008/4, which is in similar form to TA 2008/3. Where a hybrid discretionary trust will be making distributions to a complying superannuation fund or SMSF, specific advice on TA 2008/4 compliance is essential. Contact the MGS Private team for guidance on structuring trust distributions to superannuation funds.
Ordering

How to order your MGS Hybrid Discretionary Trust


1

Register or log in

Create your MGS account or log in at macquariegs.com.au. Registration is free and takes under two minutes.

2

Complete the order form

Provide the Settlor, Trustee, Appointor, Controller (if any) and Primary Beneficiary details. Our form guides you through each field required to establish both the discretionary and unit trust aspects of the deed.

3

MGS prepares your deed

Our team prepares a bespoke ATO-compliant MGS Hybrid Discretionary Trust deed to your specifications. Standard turnaround is 1–2 business days.

4

Execute and establish

The deed, binder and explanatory memorandum are delivered ready for execution by the Settlor and Trustee. The memorandum covers establishment, stamp duty obligations, and guidance on both the discretionary and unit phases — including unit issue, the 30 June resolution, and correct unit redemption procedures.

Included with your deed
  • Bespoke ATO-compliant MGS Hybrid Discretionary Trust deed
  • Explanatory memorandum (full — covering both discretionary and unit phases)
  • Trustee establishment resolutions template
  • Annual income distribution resolution templates
  • Unit application, Certificate of Units and unit redemption templates
  • Copy of the MGS Private Binding Ruling and Reasons for Decision
  • Minute book templates
  • Stamp duty guide for all Australian states and territories
  • Access to MGS technical support team
Order Now — Login / Register

Questions? Call us on (02) 9231 5111

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Postal Address: GPO Box 512
Sydney, NSW 2001, Australia
Phone: (02) 9231 5111
Email: contact@macquariegs.com.au
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