You have been told negative gearing is a tax break, and positive gearing is the cash-flow play. Neither description tells the full story. The right question is not which one is better in the abstract, but which one fits your income, your holding period, and the property you are actually buying.
And the answer matters more right now than it did 12 months ago. The 2026-27 Federal Budget has changed the rules, and the changes are already law.
How Each Structure Works
Negative gearing is the term used to describe a situation where expenses associated with an asset, including interest, are greater than the income earned from it. Individuals who are negatively geared can deduct that loss against other income, such as salary and wages.
Positive gearing is the opposite: rental income exceeds expenses. In that situation, the income above interest and other costs is taxed at the individual's marginal rate.
Both sit within the same framework. The ATO allows investors to offset the costs of earning assessable income against that income, the same principle that applies to any business.
What you can deduct when negatively geared:
- Loan interest, the interest portion of your mortgage repayments, not the principal, and only for the investment portion of the loan. This is typically the single largest deduction.
- Depreciation, the decline in value of the building (Division 43, 2.5% per year for 40 years on post-1987 construction) and plant and equipment (Division 40).
- Council rates, property management fees, insurance, repairs, and land tax.
One distinction worth understanding: a property can be tax-negative but cash-positive, this happens when depreciation (a non-cash deduction) pushes total expenses above rent, but you are not actually out of pocket. That is a meaningful difference when you are assessing real holding costs.
The Rule Change You Need to Know
This is where the landscape has shifted. On 12 May 2026, as part of the 2026-27 Federal Budget, the Government announced it would reform negative gearing and capital gains tax arrangements. These measures are now law.
Properties held at announcement (7:30pm AEST 12 May 2026) are exempt from the negative gearing changes, while the CGT reforms will only apply to gains that accrue after 1 July 2027.
For CGT, the changes are significant. The 50% CGT discount for individuals, trusts and partnerships will be replaced with cost-base indexation and a 30% minimum tax rate on capital gains. The changes will only apply to gains arising after 1 July 2027, and investors in new property builds will be able to choose between the existing discount and the new arrangements when they sell.
For properties purchased after the announcement date on existing stock, negative gearing losses will no longer be deductible against ordinary income from 1 July 2027, they will only be claimable against future rental income. A person buying a new build property can continue to negatively gear as per current arrangements.
The practical upshot: new builds retain both negative gearing access and the choice of CGT treatment. Existing properties already owned before 12 May 2026 are fully grandfathered. Properties bought after that date on existing stock face restricted deductibility from 1 July 2027 onward.
All of this warrants a careful conversation with a registered tax agent before you commit to any purchase structure. The ATO's detailed guidance is available at ato.gov.au.
The Trade-Offs Worth Weighing
Negative gearing has always rested on two legs: the annual tax deduction and the eventual capital gain. Remove or reduce either one, and the maths changes.
The higher your marginal rate, the more each dollar of rental loss saves you. For someone earning $120,000, a $15,000 rental loss reduces the after-tax cost of that loss to approximately $10,200 for the year. That deduction softens the cash-flow pain, but it does not eliminate it. You are still out of pocket every month; you are just out of pocket by less after tax.
Positive gearing, by contrast, puts money in your account from day one. Where rental income exceeds expenses, that net income is simply taxed at your marginal rate, which can be a reasonable trade-off if the yield is strong enough and your marginal rate is manageable.
Key trade-offs to discuss with a licensed adviser:
- Cash flow versus tax position. A negatively geared property requires you to fund the shortfall from your salary or other income. That requires financial capacity and reliability of employment. A positively geared property generates income, but that income is taxable and may affect your overall tax position.
- Holding period. The longer you hold, the more relevant the CGT treatment at sale becomes. Under the new rules, the CGT outcome for post-announcement existing properties is less favourable than it was under the 50% discount regime.
- Property type. New builds now carry distinct advantages: continued negative gearing deductibility and the ability to choose between the old and new CGT arrangements at sale. That is a structural difference, not just a preference.
- Your income phase. If you are approaching or in retirement and your marginal rate is falling, the annual tax deduction from negative gearing becomes less valuable. At that point, positive cash flow from a well-yielding property may be more useful.
A Worked Scenario: Two Investors, Same Property Price
Consider two investors, both buying a new build at $680,000. One is a PAYG professional earning $160,000. The other recently retired on a part-pension income of $45,000.
Investor A (higher income): Annual rental income is $30,000. Total deductible expenses, interest, management, rates, insurance, depreciation, come to $48,000. The rental loss of $18,000 is deductible against salary. At a marginal rate of 47% (including Medicare), the annual tax saving is approximately $8,460. The real after-tax holding cost is around $9,540 for the year, not $18,000. The property is negatively geared, but the tax system absorbs a meaningful portion of the shortfall. On sale after many years, this investor (buying a new build post-announcement) retains the choice of CGT treatment.
Investor B (lower income): The same property would generate the same rental income, but the $18,000 deduction is worth far less at a lower marginal rate, perhaps $3,600 at 20%. The cash flow gap is harder to justify. A positively geared property, with a higher yield and lower debt, would be a more practical fit for this investor's income position. The taxable rental income would be taxable, but manageable.
These are illustrative figures only. Actual outcomes depend on the specific property, the loan structure, depreciation schedules, and the investor's full tax position in a given year. They are not projections and should not be treated as such.
Inside an SMSF, the picture changes entirely. A complying superannuation fund that follows the laws and rules for SMSFs qualifies for a concessional tax rate of 15%. A complying SMSF generally pays 15% on its assessable income, including rent. Net capital gains on assets held longer than 12 months are effectively taxed at 10% after the one-third discount. SMSFs can receive a tax exemption on investment income received from assets that support a retirement phase income stream. This income is exempt current pension income (ECPI). At that point, both rental income and capital gains on those assets may be taxed at 0%.
For SMSF investors, positive gearing inside the fund is a practical and often attractive structure, because the rental income is taxed at 15% rather than at the member's personal marginal rate, which could be as high as 47%. An SMSF property purchase carries strict compliance requirements under the Superannuation Industry (Supervision) Act and the ATO's SMSF rules. The structure of any borrowing arrangement inside an SMSF is subject to ongoing regulatory change, and specialist SMSF legal and accounting advice is essential before proceeding.
What to Do Next
The interaction between gearing strategy, CGT treatment, ownership structure, and timing is genuinely complex, more so now than before May 2026. Here are three concrete steps worth taking.
- Get your tax picture in order. Before deciding on gearing strategy, understand your current marginal rate, your expected income trajectory over five to ten years, and how a rental property's income or loss would sit within your total tax position. A registered tax agent or licensed financial adviser can model this properly. This is not something to estimate from a blog post, including this one.
- Assess the property on yield first. Gearing strategy is secondary to the property itself. An independent rental appraisal and a realistic assessment of vacancy rates and ongoing costs should come before any tax calculation. Positive or negative gearing is a function of what the property actually produces, not what you want it to produce.
- Speak with a broker and, if relevant, an SMSF specialist accountant. Loan structure affects deductibility, cash flow, and your ability to hold through vacancy periods. If you are considering property inside an SMSF, an SMSF specialist accountant and a solicitor familiar with the SIS Act should be involved from the start, not after you have found a property.
EWC coordinates property sourcing and finance referrals for investors, owner-occupiers, and SMSF buyers. You can view our services, explore further reading on the insights page, or book a call to talk through your situation.
General information only, not personal financial advice. Speak with a licensed adviser before acting.