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An overview by Corrs Chambers Westgarth, Taxand Australia
The seven-year transitional relief for managed investment trust (MIT) cross-staple arrangement income in Australia will end on 30 June 2026 for non-economic infrastructure facilities, increasing the withholding rate for affected foreign investors from 15% to 30% from 1 July 2026.
Introduced in 2019 to address integrity concerns around stapled structures accessing concessional MIT rates, the non-concessional MIT income (NCMI) rules recharacterise certain cross-staple income and limit concessional treatment, with transitional relief available for qualifying pre-27 March 2018 arrangements.
As the relief expires, entities should assess the tax, financing, and commercial implications of operating outside the transitional regime, including impacts on rent characterisation, deductions, restructuring, tax attributes, distributions, and existing financing arrangements.
Luke Imbriano, Simon Clark, Justine Pavlidis, and Adam Stapledon from our Australian member firm Corrs Chambers Westgarth have explored the impact of the changes here.
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