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  • Amendment obligations when new member data is provided

    An existing member might provide you with a TFN, either because they previously had not given one or because the TFN they had previously given you was incorrect. In these circumstances, do not lodge an amended MCS for previous years. The new data you now have relates only to the current year and you must provide it only in the next MCS you lodge for the member. The same principles apply to other member data such as changes of name, date of birth and address.

    The MCS tells us the data you hold about a member at a point in time, so changes in one year don't require you to go back and amend for other years. The same principles apply if you receive new information from other sources such as a TFN notification from us or updated information from the member's employer.

    Example

    A member, Claire, tells her fund in December 2011 that she has changed her name, address and marital status. The fund reports the new details in the member's 2012 MCS that they lodge on 31 October 2012. The fund does not amend Claire's 2011 MCS to show the new details.

    Example

    Medlock Super is the default fund for TWH Pty Ltd. Tom's account was opened when he became an employee of TWH in March 2011 but Medlock Super has never had Tom's TFN. Medlock Super had paid no-TFN contributions tax on the employer contributions being made for Tom. They lodged a 2010–11 MCS for Tom without a TFN.

    Tom gave Medlock Super his TFN in December 2011. They report the TFN in Tom's 2011–12 MCS (but they do not amend Tom's 2010–11 MCS as they held no TFN for him that year).

    Medlock Super can claim a no-TFN tax offset in their 2011–12 tax return as no-TFN tax was payable within the most recent three income years.

    End of example

    There are two important exceptions to this principle:

    • You must amend to correct your own errors or omissions within 30 days of becoming aware of them.
    • When you are advised of a change of details but fail to report the change correctly in that year's MCS, you may need to later amend that MCS once you become aware of your error, but only when it's a material error.

    An error or omission in a member's TFN would always be a material error that would require amendment without delay.

    You are required to remove a TFN from your records if you receive a notice under section 299TB of SISA).

    The legal effect of this notice is that the members listed on the notice are taken not to have ever provided their TFN to you.

    The effect is a retrospective one – as a result of the notice, you may have an obligation to pay no-TFN contributions tax on the members' employer contributions and other taxable contributions, and must return all member contributions made by the affected members on or after 1 July 2007.

    You must also return any co-contributions to us.

    The important MCS consequence is that you must, within 30 days, amend each MCS lodged for the affected members for 2007–08 and later years. The amended MCS should not include the TFN and, where relevant, should reflect the return of any member contributions.

    This exception does not apply when you receive notices under either section 299TA or section 299TC of SISA or when you receive a section 299TC response from our SuperTICK service.

    Questions and answers

    From memory, the TFN notification file (299TA) requires an MCS amendment to be lodged dating back to 2007–08 when the original TFN has been replaced with a new valid TFN – is this not correct?

    This is incorrect (you are probably thinking of 299TB notices that do have this impact back to 1 July 2007). As discussed, there is no need to amend an MCS when you get a TA or TC notice or when a member provides a TFN for the first time. You report the new TFN in the next MCS.

    What if you are advised of an incorrect TFN for a member? Do you not have to amend to alert you of incorrect TFN previously reported. Say an employer supplied a TFN for a different member?

    If the employer made an administrative error and gave you a TFN that the member had not in fact quoted then you might decide to amend back to when this error was first made. But generally the quotation of a new number just needs to be reported in the next MCS.

    Can you please confirm if an MCS amendment is required when a TFN is changed after the ATO issues a 'Please Resolve' notice for this member?

    The Please Resolve letter was suggested by funds so they had an opportunity to locate and report the member’s correct TFN or other personal details before Section 299TB (Invalid TFN) notices are issued. Please Resolve (PR) notifications are issued where:

    • differences in personal details (TFN, name, date of birth, address, etc) between our records and the reported MCS data means we cannot be satisfied that the reported TFN matches the member being reported
    • in some instances the TFN that is reported may be correct, but we are not able to match the form.

    If your member confirms the data you hold is correct, you can encourage members to update their details with the ATO.

    To advise your members how they can update their details, refer to Update your details.

    If your member advises you of new personal details, you should update your records and amend the MCS for that member within 60 days as outlined in the electronic reporting specification or in our letters. The TFNs that you receive will be correct in our system at the time the files are issued. If the TFN notification is different from the result provided previously by other notices or online services, such as SuperTICK, you should rely upon the more recent TFN notification. The ATO is continuously matching member details with correct TFNs and the more recent data will contain a greater number of successful matches.

    Why can't the ATO use the TFN as the identifier?

    The TFN identifies the member but not the account. The issue is not matching the new MCS up with the correct member but matching the new MCS up with the previous MCS for the particular account that the new MCS is expected to amend.

    As discussed, the process could be redesigned in a number of ways but that won’t happen until we design the Fund member report that will replace the MCS.

    See also:

    Where we send two records for one instance of a member, how do you combine those records? Are all fields combined or only value fields?

    When a member has two accounts with a fund and so two MCS are lodged, we don’t combine the fields at all – the two MCS remain independently recorded in our systems. The two only come together when an assessment or entitlement process adds up the contributions recorded on each of them and decides which contributions are concessional, non-concessional, etc.

    One of the new fields in the MCS is the USI. Will these fields flow through to SuperMatch reporting in the future? This field would make the Supermatch/IRRQ production much easier.

    Thank you for your feedback. Your comment has been passed on to our Data standards and e-Commerce area.

    The use of the unique superannuation identifier (USI) is that it allows identification of a fund, or a product or other sub-division within a fund.

    All member accounts must be allocated a USI, at least for MCS reporting.

    We expect ATO payments to be made to the product level from December 2014 and so a USI is essential in 2013–14 reporting. A USI is attributed by the provider to the member’s account. The USI must be an identifier previously given by the provider to the ATO for the purposes of regulation 3B.03 of SISR and allows the ATO to direct superannuation payments and information to the correct destination (for example, to allow payments to be made to particular products within a fund).

    The identifier reported at this field must use one of the following formats:

    • the provider’s ABN followed by three digits (14 numerical characters), or
    • a super product identification number (SPIN) of nine alphanumeric characters preceded by five leading zeros to make a total of 14 alphanumeric characters.

    An MCS lodged for 2013–14 or subsequent financial years must always include a USI, even if the account is closed for ATO payments.

    Changes to contributions reporting following a rollover

    At the request of industry, we have changed the way contributions are reported when a rollover occurs. From 1 July 2013, all contributions received by a super fund during a financial year must be reported to us by that fund – not by another fund – where the contributions are rolled over to another fund. This affects the contributions reported in the 2013–14 and subsequent years MCS.

    The 2013–14 MCS (and later years) will only report contributions received directly by the super fund. You will simply need to report all contributions you have received on the MCS for all accounts held during the year, including those that have closed during the year. This change applies to the 2013–14 MCS for MCS due on or before 31 October 2014.

    These changes have only been made possible following the introduction of expanded reporting for all members and changes being introduced from 1 July 2013 for the rollover data standard. To implement this change, we have published a new rollover benefits statement (RBS) for use from 1 July 2013. There is no current year contributions information included on the new RBS. The new MCS reporting specification to be published for 2013–14 will reflect the change to reporting contributions that are rolled over and remove references to the RBS.

    See also:

      Last modified: 05 Apr 2018QC 42279