An estate that takes a while to administer keeps earning money in the meantime, and that income has to be taxed somewhere. It can stay in the estate, where it is taxed as trustee income at a flat rate, or it can be distributed to beneficiaries, where each person is taxed at their own marginal rate on their share. The difference between those two treatments is usually larger than people expect, because a flat rate has no bottom to it while individuals each start again at the lowest bracket. A beneficiary with no other income pays 10.5% on their first slice and 17.5% on the next, and every additional beneficiary brings a complete fresh set of those bands. An estate gets none of them. There is also a timing element that catches executors out. New Zealand gives deceased estates a concessional rate for a limited window after death, and when that window closes the rate on retained income steps up sharply, so an estate still being wound up in its fifth year is being taxed considerably more heavily than it was in its fourth. Two constraints pull against all of this and both need checking before anything is acted on. Distributions to young beneficiaries are largely blocked by the minor beneficiary rule, and an executor can only distribute income in the ways the will actually permits, which means the tax answer is an input to the decision rather than the decision itself.
| Treatment | Tax | Kept | Effective rate |
|---|---|---|---|
| Retained, year of death plus 3 years | $26,400.00 | $53,600.00 | 33.00% |
| Retained, once taxed as a trust | $31,200.00 | $48,800.00 | 39.00% |
| Distributed to the beneficiaries below | $16,498.33 | $63,501.67 | 20.62% |
| Saved by distributing, at the current rate | $9,901.67 | $9,901.67 | 12.38% |
The estate pays a flat rate with no low brackets. Beneficiaries each start at 10.5%, which is where the whole difference comes from.
| Beneficiary | Other income | Receives | Tax on it | Effective rate | Keeps |
|---|---|---|---|---|---|
| Beneficiary one | $0.00 | $26,666.64 | $3,574.66 | 13.40% | $23,091.98 |
| Beneficiary two | $60,000.00 | $26,666.64 | $8,256.99 | 30.96% | $18,409.65 |
| Beneficiary three | $25,000.00 | $26,666.72 | $4,666.68 | 17.50% | $22,000.04 |
| Total | $85,000.00 | $80,000.00 | $16,498.33 | 20.62% | $63,501.67 |
Beneficiary two already earns $60,000.00, so their share is taxed at close to the estate rate anyway. The saving comes almost entirely from the other two.
| Split evenly between | Each receives | Total tax | Effective rate | Saved against retaining |
|---|---|---|---|---|
| 1 beneficiary | $80,000.00 | $16,277.50 | 20.35% | $10,122.50 |
| 2 beneficiaries | $40,000.00 | $11,816.00 | 14.77% | $14,584.00 |
| 3 beneficiaries | $26,666.67 | $10,724.00 | 13.41% | $15,676.00 |
| 4 beneficiaries | $20,000.00 | $9,632.00 | 12.04% | $16,768.00 |
| 5 beneficiaries | $16,000.00 | $8,540.00 | 10.68% | $17,860.00 |
Assumes none of them has other income, which is why these rates are lower than the mixed example above. Each extra beneficiary adds a fresh 10.5% and 17.5% band.
| Estate income | Rate | Tax | Kept |
|---|---|---|---|
| $9,000.00 | 33.00% | $2,970.00 | $6,030.00 |
| $10,000.00 | 33.00% | $3,300.00 | $6,700.00 |
| $10,001.00 | 39.00% | $3,900.39 | $6,100.61 |
| Effect of $1.00 more income | up 6 points | $600.39 | -$599.39 |
One extra dollar of trustee income costs $599.39, because the higher rate applies to the whole amount rather than just the excess.
The reason distribution usually wins is structural rather than clever.
An estate pays one rate on every dollar, starting from the first. An individual pays 10.5% on their first $15,600.00 and 17.5% up to $53,500.00, so a beneficiary with no other income is taxed at an effective 20.35% on $80,000.00 against the estate's flat 33%.
Every additional beneficiary brings another complete set of those bands. That is the whole mechanism, and it is why the saving grows with the number of people the income is split between.
Retained during the concession: $26,400.00 of tax, leaving $53,600.00.
Retained after it ends: $31,200.00, leaving $48,800.00.
Split three ways between someone with no other income, someone earning $60,000.00, and someone earning $25,000.00: $16,498.33 of tax, leaving $63,501.67.
That is $9,901.67 saved a year against retaining now, and $14,701.67 against retaining once the estate is taxed as a trust.
The mixed example above is worth reading carefully, because the three beneficiaries contribute very differently.
The beneficiary with no other income is taxed at 13.40% on their share. The one earning $25,000.00 pays 17.50%. The one already earning $60,000.00 pays 30.96%, which is barely below the estate's 33% and saves almost nothing.
So the benefit is concentrated in beneficiaries with spare capacity in their lower brackets. Distributing to someone already on a high income achieves very little, and above $180,000.00 of other income it would actively cost more than retaining.
The concessional 33% rate applies for the tax year of death and the next 3 years, and then it stops.
On $80,000.00 of income that step costs a further $4,800.00 every year the estate continues. An estate still holding income-producing assets in its fifth year is being taxed noticeably harder than it was in its fourth, for no reason connected to the estate itself.
That makes the fourth anniversary a sensible review point rather than a date to discover afterwards. Where administration is genuinely going to run long, the case for distributing income as it arises strengthens considerably.
Once the estate is taxed as an ordinary trust, trustee income of $10,000.00 or less attracts 33% rather than 39%, and the threshold is a cliff.
An estate with $10,000.00 of income keeps $6,700.00. One with $10,001.00 keeps $6,100.61. A single extra dollar costs $599.39, because the higher rate reprices the whole amount rather than just the excess.
For a small estate near that line, distributing enough income to stay under it can be worth considerably more than the amount distributed. Our investing through a trust calculator covers the same threshold in an ordinary trust.
Having seen that splitting across more people lowers the tax, the natural next thought is to include grandchildren. That mostly does not work.
The minor beneficiary rule generally taxes trust distributions to beneficiaries under 16 as trustee income at 39%, which removes the advantage entirely. Exceptions exist, including where distributions to that beneficiary total $1,000.00 or less in the year, but the rule is deliberately there to stop this.
The will governs. An executor cannot allocate income to whoever is taxed least. They must follow the will's terms and owe duties to all beneficiaries, so these splits are only available where the will genuinely permits them.
One distinction removes a lot of confusion. Distributing the estate's capital to beneficiaries is not income and is not taxed as income in their hands.
Everything on this page concerns income the estate earns while it is being administered: interest on bank accounts, dividends on shares still held, rent on a property not yet sold. That income has to be taxed to someone each year, and the only question is whether that someone is the estate or a beneficiary.
Distributing the underlying assets sooner ends the question entirely, since income earned after that point simply belongs to whoever now owns them. Our child investment account calculator covers how income is taxed once assets are held for a young person directly.