I support the intent of this bill, which is to tax income in a broadly similar way whether it comes from work or from wealth, and I welcome the changes the government has made following consultation, including the electable regime and rollover relief. But we're asking family businesses to make significant decisions quickly without knowing what those decisions will cost—Treasury puts the average cost of restructuring at around $11,000; COSBOA puts it at $15,000 to $50,000 before stamp duty—and the window for making a decision closes early, with rollover relief ending on 30 June 2030.

My amendments would make sure we find out how this reform is affecting small business while there's still time to fix any problems. These amendments insert a new schedule, 3A, which sets up two reviews. The first is an early inquiry by the Small Business and Family Enterprise Ombudsman. The minister would ask the ombudsman by 1 July 2029 to inquire into how the trust changes are affecting small business, using the ombudsman's existing inquiry powers. The ombudsman would report by 31 March 2030, three months before rollover relief closes, and the report would be tabled in parliament. The ombudsman would look at how small businesses are using rollover relief and the option to fix beneficiaries and stay outside the minimum tax and whether those settings, including the June 2030 end date, should change. It would look at what businesses are really paying to adjust, including professional fees and state stamp duty, it would look at whether ATO guidance and support are adequate, and it would look for any unintended consequences. The amendment also lets the ombudsman request aggregate data from the Commissioner of Taxation on rollovers and elections. No individual or business would be identified, but it would give the ombudsman hard data to consider alongside what small businesses are saying. The timing of this review is important. If costs turn out much higher than expected or ATO guidance arrives late, we need to know before the deadline for rollover relief passes, not after businesses have made decisions that they can't undo. A report in March 2030 gives the parliament time to extend the deadline if it needs to do so.

The second review is a full, independent review of the trust amendments. At the moment, the bill requires no review at all, which is a significant gap for a reform that impacts 840,000 discretionary trusts. This amendment would require an independent review to begin between July 2030 and January 2031, once there's tax data to show how the new rules are working in practice. It must be conducted by people who are not officials of Treasury or the ATO, completed within nine months and tabled within 15 sitting days. The review would go back to the purpose of the bill and ask: has it brought the taxation of trust income closer to the taxation of income from work? It would compare actual revenue and compliance costs with the published estimates and identify which income and wealth groups have ended up paying more. On small business, it would look at how much additional tax has been paid, what restructuring really costs and the effect on investment and succession planning. It would examine how people have changed their structures, including any shift towards companies, and it would examine how the commissioner and the minister have used their discretionary powers under the rollover and election regimes—because powers of this kind should be open to scrutiny.

These amendments don't change the tax, and they don't cost the budget. They simply make sure parliament sees the real-world impact of this reform, not just the modelling, and has the chance to respond. Getting the detail right is how this reform can keep the community's support. I call on the government to support these amendments and commit to these reviews. I commend the amendments to the House.