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  • What and when to report

    A self-managed super fund (SMSF) must report certain events in the event-based reporting framework for self-managed super funds (SMSFs) to the ATO by the due dates.

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    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 us
    • 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 super transfer balance account report (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.

    In line with our valuation guidelines for self-managed super funds, the SMSF trustee may choose to use a reasonable estimate of the value of an income stream to meet their TBAR obligations when the pension commences part way through a year or the pension commenced on 1 July and you need to report this event to us by 28 October and a full valuation of the assets supporting the pension is not possible by this date (for example, they include private company shares).

    We expect that as part of choosing to commence a pension, an individual will be in possession of a reasonable estimate of the value of that pension and have taken that into consideration as part of both their broader financial planning and as part of ensuring that commencing the pension will not result in them exceeding their transfer balance cap. In some instances it may be prudent to bring forward the usual valuation practices.

    If the trustee has used a reasonable estimate and the value of that income stream significantly changes, the trustee may choose to correct the value initially reported to us.

    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 SMSF annual return (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.

    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. This is even if the balance of the first member to start a retirement phase income stream is below $1 million.

    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. If the member's pension account is being rolled over because the SMSF is wound up, the TBAR should be lodged before the fund is wound up and you should report the account as closed.

    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 is due 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 an 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. We don't intend to deny exempt current pension income (ECPI) claims if an SMSF doesn’t report their transfer balance cap on time.

    Record keeping

    Trustees have an obligation to ensure:

    • that their TBAR reporting is true and correct
    • the commencement and commutation of retirement phase income streams is supported by contemporaneous fund records
    • payments to members have been correctly characterised and allow trustees and auditors to ensure that the minimum pension payment standards have been met. This is especially important where pension payments have been made from an income stream that has also been commuted in full or in part during the year
    • their TBAR reporting in relation to the commencement and commutation of retirement phase income streams also aligns with their ECPI claim for a year.

    Trustees will need to ensure that the relevant documentation is clearly passed on to their auditor.

    Amended reporting

    TBAR re-reporting by SMSF trustees will be monitored and we may request evidence of relevant documents and calculations to substantiate the TBAR amendment.

    Last modified: 23 Jul 2019QC 57300