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  • What and when to report

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    What events you need to report

    An SMSF must report events that affect a member's transfer balance, including:

    • details of pre-existing income streams (including value and type) being received on 30 June 2017 that      
      • continued to be paid to them on or after 1 July 2017
      • were in retirement phase on or after 1 July 2017
       
    • details of new retirement phase and death benefit income streams including value and type (when a death benefit income stream is reversionary, the start date will be the date on which the member died)
    • details of limited recourse borrowing arrangement (LRBA) payments (including the value and date of each relevant payment) if the LRBA was entered into on or after 1  July 2017 (or a pre-existing LRBA was re-financed on or after 1 July 2017) and the payment results in an increase in the value of the member's interest that supports their retirement phase income stream
    • compliance with a commutation authority issued by the Commissioner
    • details (including value) of personal injury (structured settlement) contributions
    • details (including value) of commutations of retirement phase income streams that occur on or after 1 July 2017.

    If no event occurs you have nothing to report.

    Some exclusions from reporting

    Events that an SMSF does not need to report include:

    • any pension payments made on or after 1 July 2017
    • investment earnings and losses that occurred on or after 1 July 2017
    • when an income stream ceases because the interest has been exhausted
    • the death of a member
    • information that individuals report to us directly using a Transfer balance event notification form (NAT 74919). Typically, this is when the following events occur  
      • family law payment split
      • debit event from fraud, dishonesty, or bankruptcy
      • structured settlement contributions made before 1 July 2007.
       
    • information other funds will report to us, such as a member's interest in an APRA fund.

    See also:

    How often and when you need to report

    If an SMSF member had a pre-existing income stream, it needed to have been reported to us on the TBAR on or before 1 July 2018.

    From 1 July 2018, all SMSFs must report events that affect their members' transfer balances. If no event occurs, there is nothing to report. Timeframes for reporting are determined by the total superannuation balances of an SMSF's members.

    SMSFs that have any members with a total superannuation balance of $1 million or more on 30 June the year before the first member starts their first retirement phase income stream, must report events affecting members’ transfer balances within 28 days after the end of the quarter in which the event occurs.

    When all members of an SMSF have a total superannuation balance of less than $1 million, the SMSF can report this information at the same time as when its SAR is due.

    Transfer balance account events that occur during 2017–18 should be reported when an SMSF's first TBAR is due.

    If an SMSF is reporting annually, this will be the same time as the trustee is due to lodge the 2017–18 SAR.

    If an SMSF is reporting quarterly, this will be 28 October 2018.

    An SMSF is required to report earlier if a member has exceeded their transfer balance cap.

    Any SMSF can choose to report events as they occur and in some instances are encouraged to do so to avoid incorrect excess transfer balance determinations issuing.

    See also:

    To work out if the quarterly or annual reporting arrangements apply, an SMSF will need to know the total superannuation balance of all of its members at the later of:

    • 30 June 2017 if a member had a pre-existing income stream in retirement phase or when the first member starts their first retirement phase income stream during the 2017–18 year
    • 30 June the year before the first member starts their first retirement phase income stream.

    Even when an SMSF has only one member with an individual total superannuation balance of $1 million or more, it must report all events for all members within 28 days after the end of the relevant quarter, even if the balance of the first member to start a retirement phase income stream is below $1 million.

    See also:

    Once the reporting framework is set, SMSF trustees will not be expected to move between annual and quarterly reporting, regardless of fluctuations to any of the members' balances.

    We will continue to evaluate the benefits and risks arising from this reporting framework. For example, the $1 million reporting threshold may be re-evaluated in the future, given that the $1.6 million transfer balance cap is indexed.

    See also:

    Total superannuation balance

    A member's total superannuation balance is essentially the sum of all their accumulation and retirement phase superannuation interests across all their accounts and funds.

    In recognition that a member's total superannuation balance could be spread across multiple superannuation providers, SMSF trustees will need to self-assess their members' total superannuation balances when determining if the annual or quarterly reporting framework applies as there may be outstanding information yet to be reported to us.

    Trustees are expected to demonstrate that they have taken a fair and reasonable approach to assess their members' total superannuation balances when determining if the annual or quarterly reporting framework applies.

    See also:

    When you need to report sooner

    If a member exceeds their transfer balance cap, you must report the following events sooner:

    • a voluntary member commutation of an income steam in response to an excess transfer balance (ETB) determination must be reported within 10 business days after the end of the month in which the commutation occurs
    • responses to commutation authorities must be reported within 60 days of the date the commutation authority was issued.

    Earlier reporting is encouraged in some situations

    We strongly encourage you to report earlier in some situations.

    For example, if an SMSF member rolls their super benefit into an APRA-regulated fund and starts an income stream there – and it is not reported to us by the SMSF at the time it happens – a double-counting of the member’s income streams will occur. This is because there will be a mismatch in timing of the reporting done by the APRA-regulated fund and the SMSF. In this instance, an SMSF is encouraged to report the commutation as it occurs, or no later than at the time of the rollover.

    Likewise, if the transitional rules apply and an SMSF member was in excess at 1 July 2017 and rectifies it by 31 December 2017 but does not report the rectification to us when the pre-existing income stream is reported, we will not know the member has rectified the excess. In this instance, an SMSF is encouraged to report the commutation that rectifies the small excess under the transitional rules at the time the pre-existing income stream is reported.

    In these situations, there is risk we will incorrectly issue an ETB determination and a commutation authority. This could lead to increased administrative costs for the SMSF.

    See also:

    Working out your reporting due date

    When a member of the fund has a pre-existing income stream that continues to be paid as a retirement phase income stream to the member on or after 1 July 2017, the TBAR due date is on or before 1 July 2018.

    For SMSFs with transfer balance account (TBA) events occurring in 2017-18 and future years, the following table will help you work out your reporting due date.

    Table 1: Due dates for reporting TBA events

    Transfer balance account (TBA) event

    Amount of SMSF members' total superannuation balance (TSB)

    TBAR due date

    A voluntary member commutes an income stream in response to an excess transfer balance (ETB) determination

    Not applicable, as member has exceeded their TBC

    Within 10 business days after the end of the month in which the commutation occurs

    A response to a commutation authority

    Not applicable, as the reporting obligation is set by legislation

    Within 60 days of the date the commutation was issued

    Any other TBA event – see What events you need to report

    When the first member started a retirement phase income stream during a year, and all members of the SMSF had a TSB of less than $1 million as at 30 June immediately before they started their income stream

    No later than the due date for lodging the SMSF's annual return for the financial year in which the event occurs

    Any other TBA event – see What events you need to report

    When the first member started a retirement phase income stream during a year and the SMSF had any member with a TSB of $1 million or more as at 30 June immediately before they started their income stream

    28 days after the end of the quarter in which the event occurred. For 2017-18 TBA events, this will be 28 October 2018.

    Once the reporting framework is set, SMSF trustees will not be expected to move between annual and quarterly reporting due dates, regardless of fluctuations in any of its members' balances or members leaving or joining the SMSF.

    Consequences of late reporting

    Unless a member has exceeded their cap and the fund needs to report an event sooner, the first due date for the lodgment of transfer balance account reports (TBARs) is 28 October. There has been no change to this previously announced date. We first announced this date on 9 November 2017.

    We are currently taking and educative and supportive approach where TBARs are lodged late. We encourage you to lodge your transfer balance reporting as soon as possible to avoid adverse consequences for members of the fund.

    If an SMSF does not lodge a TBAR by the required date, the member’s transfer balance account will be adversely affected, the member may be penalised and there may be reverse workflow for the trustee.

    In particular, if the SMSF is late reporting a commutation made after we issued an excess transfer balance determination to the member, we may send a commutation authority to their fund, putting the member at risk of having the excess amount removed from retirement phase twice.

    In the future, an SMSF may be subject to compliance action and penalties, although we don't intend to deny exempt current pension income (ECPI) claims if an SMSF doesn’t report their transfer balance cap on time.

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    Last modified: 07 Nov 2018QC 57300