Key Highlights

  • CPA Australia estimates additional annual costs of $295 million to $542 million.
  • Its separate trust estimate is $221 million to $595 million annually.
  • The two estimates total approximately $516 million to $1.137 billion per year.
  • Separating gains around the July 2027 transition creates valuation and record-keeping work.

The cost of complying with Australia's Capital Gains Tax overhaul is emerging as a flashpoint in the Senate. CPA Australia estimates the CGT reforms alone could add between $295 million and $542 million a year in compliance costs. Treasury's estimate for the trust measures in the same package is $48 million a year. With the committee due to report tomorrow, 13 November, the gap between those figures goes to whether the package is ready.

Where the $542 million figure comes from

The estimate is in CPA Australia's submission to the Senate Economics Legislation Committee inquiry into the Tax Reform No. 3 Bill and the Minimum Tax on Discretionary Trusts Bill. The submission puts the extra cost of the CGT reforms at $295 million to $542 million a year.

That is on top of CPA Australia's estimate for the trust measures. Its tax policy lead, Jenny Wong, told the committee the trust rules would carry ongoing costs of $221 million to $595 million a year. Together, the two estimates come to about $516 million to $1.137 billion a year.

These are estimates from a professional body that represents accountants.

Treasury's numbers and the $91-an-hour question

Treasury's Impact Analysis for the trust measures puts one-off implementation costs at $939 million, within a range of $780 million to $1.1 billion. It adds $48 million a year in ongoing costs and assumes an average restructure costs about $11,000.

Ms Wong called the $48 million figure a "gross underestimation". Her own estimates put one-off advice costs at $2 billion to $2.8 billion. She said that once Payday Super and other changes were included, ongoing costs could exceed $1.1 billion a year.

Her main criticism concerned the hourly rate. She said Treasury prices professional advice at about $91 an hour, well below what families pay accountants and lawyers at commercial rates. On simple arithmetic, an $11,000 restructure at $91 an hour buys about 121 hours of work. At higher commercial rates, the same budget buys far fewer hours.

The government has not conceded that its estimates are wrong. Treasury projects the trust measures will raise $4.5 billion a year by 2029–30. The Tax Institute, meanwhile, has urged the Senate not to rush the package before the rules are complete.

What is already law and what is still a bill

It helps to separate what has passed from what is still before Parliament.

The headline CGT change is already ENACTED. Under the Tax Reform No. 1 Act 2026, the 50% CGT discount is replaced by cost-base indexation and a 30% minimum tax for gains accruing from 1 July 2027. That is a minimum tax, not a "30% discount". The same Act limits negative gearing to new builds for properties bought after 7.30pm AEST on 12 May 2026, from 1 July 2027, with existing holdings grandfathered. The Reserve Bank's November Statement on Monetary Policy attributes the recent fall in housing prices mainly to monetary policy and the Budget tax changes.

The Tax Reform No. 3 Bill is a BILL and not yet law. It was introduced on 14 October and passed the House on 29 October. It carries further CGT measures, including rules on changing residency, together with the trust package. Under the bill, some expatriates who treat an Australian home as their main residence could face a deemed disposal on 30 June 2027 and lose the exemption on the pre-July 2027 gain.

Why valuations are a big part of the cost

Much of the CGT compliance burden comes from working out what Assets were worth when the new rules start.

ATO GUIDANCE published on 19 October says taxpayers may need the Market Value of an asset as at immediately before 1 July 2027, when a deemed disposal and reacquisition occurs. The ATO says people do not need a valuation in place on that date and should not get one early, because "a valuation can't be forward-looking".

The ATO also says the alternative apportionment method is "still being developed" by the government, and that its own guidance will follow once the method is enacted. Planned guidance covers valuation methods by asset type, which professionals to use and record-keeping. Tools and calculators are "under consideration".

CA ANZ told the Senate that ATO valuation guidance was still outstanding and warned that heavy Demand for valuers would make timely valuations difficult. That kind of bottleneck tends to push fees up.

The stakes can be large. In July, JLL modelled a Sydney property bought for $800,000 in 2020, valued at $1.2 million in mid-2027 and sold for $1.8 million in 2032. Tax came to about $208,680 using a professional valuation, compared with $266,960 under the ATO default formula, a difference of $58,280.

Hypothetical example: one investor's advice bill

Hypothetical example: Daniel holds two Investment properties and a share portfolio. The fees and hours here are assumptions for illustration, not quoted market rates.

He pays $600 for each property valuation, or $1,200 for two. His Accountant spends four hours on the CGT reset across his assets, at $250 an hour, which is $1,000. His total is $2,200.

If the same four hours were priced at Treasury's assumed $91 an hour, the advice component would be $364 rather than $1,000. With the valuations, the total would be $1,564. On these assumptions, the hourly rate alone accounts for a $636 difference for one investor.

Across hundreds of thousands of investors, small differences like this add up. That is the core of the profession's argument that official estimates understate the real cost.

What to watch

The Senate Economics Legislation Committee report is due on Friday 13 November 2026. It may address compliance costs, valuation guidance and calls for a delay, although its recommendations are not yet known.

The government is reportedly aiming to pass the package in the third week of November. That timing depends on securing Greens support in the Senate.

ATO guidance on valuations and the alternative apportionment method will follow once the government finalises the method. The Mid-Year Economic and Fiscal Outlook is due in December.

The new CGT settings start on 1 July 2027, and the minimum tax on discretionary trusts is due to start on 1 July 2028.