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  • Transitional CGT relief

    Transitional capital gains tax (CGT) relief is temporary relief available to trustees of superannuation funds including self-managed super funds (SMSFs) who adjust their asset allocations to comply with the transfer balance cap, and transition-to-retirement income stream (TRIS) reforms, that commenced on 1 July 2017.

    To prepare for the transfer balance cap reforms, individuals may have needed to reduce amounts currently supporting superannuation income streams. They might have done this by transferring value from the retirement phase to the accumulation phase. Additionally, where individuals have a TRIS that is not in retirement phase, earnings on assets supporting these superannuation income streams became taxable from 1 July 2017.

    The relief ensures that for certain assets that were supporting superannuation income streams in retirement phase prior to 1 July 2017, a trustee can still receive a tax exemption on capital gains accrued but not realised.

    Applying CGT relief will:

    • reset the cost base of an asset to its market value. The market value would be determined under the Valuation guidelines for self-managed super funds on the date the relief applies
    • allow you to defer a capital gain that arises when resetting the cost base for assets where you use the proportionate method.

    Objective of CGT relief

    The object of the CGT relief provisions is to provide temporary relief from certain capital gains that might arise as a result of complying with the introduction of the transfer balance cap, or the TRIS reforms.

    As a trustee of a fund, you should ensure that any choices regarding the application of CGT relief to assets are consistent with this objective.

    Due to the introduction of the transfer balance cap on 1 July 2017, a member may have needed to reduce amounts supporting retirement phase super income streams to ensure their total amounts in retirement phase did not exceed $1.6 million. CGT relief may be available in these situations.

    From 1 July 2017 assets supporting a TRIS lost their tax exemption on earnings, unless the TRIS is in retirement phase. A TRIS is no longer considered a super income stream in retirement phase, unless your member satisfies a condition of release with a nil cashing restriction. CGT relief may be available where assets were supporting a TRIS that is not in the retirement phase.

    For funds with a member who was in receipt of a TRIS that continues to be in the retirement phase, CGT relief may be available where amounts supporting this TRIS are reduced in order to comply with the transfer balance cap rules.

    When CGT relief isn’t available

    CGT relief is only available in the above circumstances. If a fund did not have members making changes who needed to reduce amounts supporting retirement income streams below the $1.6 million transfer balance cap, or members with a TRIS who are affected by the changes, the trustee cannot apply CGT relief.

    CGT relief will not be available to a fund purely because they need to use the proportionate method to calculate their exempt current pension income (ECPI) due to new restrictions. For 2017–18 onward, an SMSF trustee will be required to use the proportionate method if a member had a total superannuation balance over $1.6 million at the end of the previous financial year, and that member is receiving an income stream from any source.

    Note that these restrictions only relate to the ability for an SMSF to segregate for the purposes of claiming ECPI. Even though the SMSF may be required to use the proportionate method to calculate its ECPI, the trustee can still decide which assets will support income streams for investment returns.

    CGT relief and the general anti-avoidance rules

    As noted above, the CGT relief provisions have an intended purpose. Therefore, schemes designed to maximise an entity’s CGT relief or to minimise the capital gains of existing assets in accumulation phase, for example, by creating the circumstances to give access to CGT relief, may be subject to the general anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936.

    The kinds of arrangements that the Commissioner will scrutinise carefully with a view to determining whether Part IVA applies will exhibit the following features:

    • they place the taxpayer in a position to make the choice
    • they go further than is necessary to provide temporary relief from CGT because members are complying with the reforms commencing, and
    • they demonstrate that the dominant purpose of entering into the arrangement is to avoid tax.

    See also:

    • LCG 2016/8 Superannuation reform: transitional CGT relief for complying superannuation funds and pooled superannuation trusts – refer to paragraphs 42 to 50C for more information on the transitional CGT relief and anti-avoidance

    Criteria for eligibility for CGT relief

    If you choose to use CGT relief, it will apply differently depending on what method you were using to calculate your ECPI at the start of the ‘pre-commencement period’. The pre-commencement period is the period from 9 November 2016 to 30 June 2017.

    You may have calculated your ECPI by selecting specific assets to support your income streams (known as the segregated method), or by allocating a percentage of your income streams (known as the proportionate method).

    If all of the members of the fund are receiving account-based income streams, and 100% of the fund’s assets are supporting these income streams, the assets will meet the definition of segregated current pension assets. This is known as being ‘100% in pension phase’. In this situation, we accept that the fund is using the segregated method, even though it doesn’t specifically identify its assets as segregated to support a particular income stream.

    Some criteria must be met in all situations:

    • your fund must have held the asset throughout the entire pre-commencement period
    • your fund must have been a complying superannuation fund from the 9 November 2016 until the date relief is applied.

    If you calculated your ECPI using the segregated method at 9 November 2016

    You are able to apply relief if you moved an asset from supporting the retirement phase to the accumulation phase before 1 July 2017, if your fund:

    • used the segregated method throughout the pre-commencement period, and
    • had a member who had to comply with the introduction of the transfer balance cap or TRIS reforms.

    This resets the asset’s cost base to its market value at that time.

    You are deemed to have sold and repurchased the asset for market value on the day it ceased to be a segregated current pension asset. The resulting gain or loss is entirely disregarded. This is consistent with the fact that the unrealised gain up to this point would have been exempt from income tax if the asset were sold on this day.

    You should clearly document the date the assets ceased to be segregated current pension assets.

    Example:

    John is 65 years old and retired with a retirement phase income stream that has a value of $2 million on 1 March 2017.

    John’s fund holds the following assets:

    • A property purchased on 1 December 2002 with a cost base of $300,000 (the market value of the property was $500,000 on 1 March 2017), and
    • $1.5 million in cash and shares.

    The fund uses the segregated method, with all assets supporting John’s income stream. All of these assets were held throughout the period 9 November 2016 to 30 June 2017.

    On 1 March 2017, John transfers $500,000 from his retirement phase to the accumulation phase, to ensure he complies with the transfer balance cap.

    John’s Fund transfers the property (valued at $500,000) out of the pool of segregated current pension assets supporting John’s income stream, to support John’s new accumulation phase interest.

    John’s Fund applies CGT relief to the property and its cost base is reset to its market value of $500,000 on 1 March 2017. The $200,000 capital gain is entirely disregarded as the property was a segregated current pension asset at the time of the deemed sale (1 March 2017). The gain on this asset, up to this point, would have been exempt from income tax if the asset was sold while it was a segregated current pension asset.

    The date John’s Fund is deemed to have repurchased the asset for market value is 1 March 2017 as this is when it ceases to be a segregated current pension asset.

    John’s Fund is not able to use the segregated method in 2017–18, and has to use the proportionate method to calculate EPCI; because John’s total superannuation balance exceeds $1.6 million on 30 June 2017.

    End of example

    You are able to apply relief to some or all of the assets that were previously segregated, if your fund:

    • used the segregated method on 9 November 2016
    • switched to the proportionate method during the pre-commencement period or at the start of 1 July 2017 where the switch is due to assets supporting a TRIS that is not in the retirement phase, and
    • had a member who had to comply with the introduction of the transfer balance cap or TRIS reforms.

    Instead of transferring specific assets to support the accumulation phase, you may have switched to the proportionate method (for example, where you had large assets with high market values, but your members only needed to commute a small amount back to the accumulation phase, as assets cannot be partially segregated).

    All your assets that were segregated to support income streams ceased to be segregated from the day you switched methods. This is the cessation time. You can choose to apply CGT relief to some or all of these assets to reset their cost base(s) to their market value at the cessation time. The gain or loss is entirely disregarded.

    As you will start to have assets that support both accumulation and retirement phase interests, you are required to obtain an actuarial certificate to support the use of the proportionate method to calculate ECPI.

    Example:

    Serge and Stephanie are the members and trustees of the SSF Superannuation Fund. The fund has the following member interests and assets at 9 November 2016:

    Member interests at 9 November 2016

    Interest

    Value

    Serge – Account Based Pension

    $600,000

    Serge – Accumulation

    $400,000

    Stephanie – TRIS

    $1,300,000

    Fund Assets at 9 November 2016 (segregated)

    Name

    Cost Base

    Market Value

    Asset A

    $1,500,000

    $1,900,000

    Cash

    N/A

    $400,000

    The fund uses the segregated method to calculate its ECPI: Asset A is a segregated current pension asset supporting Serge’s account based pension and Stephanie’s TRIS.

    Stephanie is under 65 and still working, and her TRIS is no longer eligible for ECPI from 1 July 2017 onwards. Stephanie still wants to continue her TRIS in 2017–18.

    On 1 July 2017, Stephanie’s TRIS is not a retirement phase income stream, and assets supporting it are no longer segregated current pension assets. The fund cannot identify specific assets supporting Stephanie’s TRIS, so it switches to the proportionate method on 1 July 2017.

    CGT relief is available for Asset A as:

    • the fund meets the object of the CGT relief provisions because Stephanie’s TRIS is excluded from being in the retirement phase
    • Asset A meets the eligibility criteria for CGT relief because
      • it was a segregated current pension asset on 9 November 2016
      • it ceased being a segregated current pension asset at the start of 1 July 2017 because it was supporting Stephanie’s TRIS
      • the fund held Asset A for the entire period from 9 November 2016 to 30 June 2017.

    The fund elects to apply CGT relief to Asset A, resetting its cost base to its market value on 1 July 2017. The capital gain arising out of the application of CGT relief is disregarded as the deemed sale for CGT relief occurred on 30 June 2017, while Asset A was a segregated current pension asset.

    In the CGT Schedule to its 2017 Self-managed superannuation fund annual return, the fund selects ‘Yes’ at label 8F – Have you chosen to apply the transitional CGT relief for superannuation funds?’. The fund needs to keep records of the new cost bases of its assets so that it can calculate its capital gains tax correctly when assets are sold.

    End of example

    If you calculated your ECPI using the proportionate method

    You can choose to apply CGT relief to some or all of your assets to reset their cost bases to their market values at 30 June 2017, if your fund:

    • used the proportionate method throughout the pre-commencement period
    • had a member who had to comply with the introduction of the transfer balance cap or TRIS reforms.

    You may make a capital gain from this reset. Where these assets have only been partially supporting income streams, you may have to pay tax on some of the capital gain.

    You can recognise any capital gain or loss in the 2016–17 year and the CGT discount may apply if you held the asset before 1 July 2016. The capital gain or loss is included in your net capital gains calculation for the year, alongside other capital gains or losses for the year, and any carried-forward capital losses.

    Alternatively you can choose to apply the CGT relief and defer the capital gain. You need to calculate the capital gain as if it were not being deferred, taking into account any applicable discount, but not applying any capital losses. The calculated capital gain is then deferred and recognised in the year that you cease to hold the asset. You cannot defer a capital loss, although you can carry it forward under the ordinary rules for capital losses.

    Example:

    Craig and Julie are the members and trustees of their SMSF, the CJ Superannuation Fund. The fund has the following interests and assets at 9 November 2016.

    Member interests

    Interest

    Value

    Craig – Account Based Pension

    $2,000,000

    Julie – Accumulation

    $1,000,000

    Fund Assets (~66% exempt)

    Name

    Cost Base

    Market Value

    Asset A

    $2,500,000

    $2,650,000

    Asset B

    $250,000

    $350,000

    The CJ Superannuation Fund uses the proportionate method to calculate its ECPI and has been doing so for several years. In 2016–17, the funds exempt proportion as calculated by an actuary is 66%.

    To comply with the transfer balance cap, Craig partially commutes $500,000 of his income stream account back to the accumulation phase on 30 June 2017, leaving him with an income stream worth $1.5 million.

    The combined cost base for both assets is $2.75 million, meaning that it had already accrued unrealised capital gains of $250,000 at 9 November 2016. However, the fund anticipates having a greater exempt proportion by the time the assets will be sold, as Julie is close to retirement.

    Therefore, the fund does not apply CGT relief and the cost base of the assets remains $2.5 million and $250,000 for assets A and B respectively.

    End of example

    If you changed from the proportionate method to the segregated method between 9 November 2016 and 30 June 2017

    In these circumstances you are not eligible for CGT relief under either the segregated or proportionate method.

    Example:

    Angela and Peter are the members and trustees of their SMSF, the AP SMSF. The members have the following interests in the fund at 9 November 2016:

    • Angela has an accumulation interest valued at $625,000
    • Peter has an account-based pension valued at $1.8 million.

    The AP SMSF uses the proportionate method to calculate its ECPI and has been doing so for several years.

    On 2 January 2017, Angela commences an account-based income pension using her entire accumulation interest. From this date, the fund’s assets meet the definition of segregated current pension assets, as they are only supporting account-based income streams (that is, the fund is ‘100% in pension phase’).

    The fund isn’t eligible for relief under:

    • the segregated method, as the fund was not using the segregated method at 9 November 2016, or
    • the proportionate method, because the assets became segregated current pension assets during the commencement period.

    CGT relief is not available for the fund, despite the fact that Peter needed to commute amounts out of retirement phase to prepare for the transfer balance cap.

    End of example

    Deferring the capital gain under the proportionate method

    If you choose to defer a capital gain that arises in applying CGT relief under the proportionate method, you must look at the capital gain to be deferred in isolation and recognise this gain in the year in which a ‘realisation event’ happens to the asset. Generally this will be when the asset is sold.

    This is done by determining the ‘deferred notional gain’ for the asset. The deferred notional gain is calculated with the following steps:

    • First, determine the capital gain made on the deemed disposal. Any current year capital losses are not recognised to apply to this amount. Previous years capital losses are also not applied in calculating the gain to be deferred.
    • If the asset was acquired before 1 July 2016, the CGT discount can be applied.
    • Then, apply the exempt portion for the 2016–17 income year.

    When this asset is later sold, or another ‘realisation event’ happens to the asset, the deferred capital gain is recognised. This deferred gain will not be discounted in the realisation year, however it is to be reduced by capital losses made in that year as well as carried forward losses. Any exempt proportion applied for the realisation year does not apply to the deferred gain, as the relevant exempt proportion from the 2016–17 year was applied to this deferred gain.

    Capital losses from CGT relief cannot be deferred, but they can be carried forward. Unlike a deferred capital gain, these losses are not reduced by the relevant exempt proportion for the 2016–17 income year.

    Example:

    Gary and Gillian are the members and trustees of their SMSF, the GG Superannuation Fund. The GG Superannuation fund has the following assets and member interests at 30 June 2017:

    Member interests

    Interest

    Value

    Gary – Account Based Pension

    $2,000,000

    Gary – Accumulation

    $500,000

    Gillian – Account Based Pension

    $1,000,000

    Fund Assets (~85% exempt)

    Name

    Cost Base

    Market Value

    Asset A

    $1,150,000

    $1,600,000

    Asset B

    $610,000

    $700,000

    Asset C

    $900,000

    $1,200,000

    The GG Superannuation Fund uses the proportionate method to calculate its exempt current pension income, and has been doing so for several years. In 2016–17, the fund’s exempt proportion as calculated by an actuary is 85%.

    On 30 June 2017, Gary commutes $400,000 out of his account based pension, and directs it into his accumulation account.

    CGT relief is available for all three of the fund’s assets as:

    • the fund meets the object of the CGT relief provisions because Gary needed to commute amounts out of retirement phase due to avoid exceeding the transfer balance cap
    • the assets meet the eligibility criteria for CGT relief because
      • the assets were not segregated current pension assets at any time during the pre-commencement period (as the fund used the proportionate method for the entire income year)
      • the fund held the assets for the entire pre-commencement period
      • the fund’s 2016–17 exempt proportion was greater than nil.

    The fund elects to apply CGT relief to all three assets, resetting their cost bases to their market values at 30 June 2017. The fund has capital gains for the three assets that are not disregarded:

    Fund assets

    Name

    Cost Base

    Market Value

    Capital Gain

    Discounted Capital Gain

    Asset A

    $1,600,000

    $1,600,000

    $450,000

    $300,000

    Asset B

    $700,000

    $700,000

    $90,000

    $60,000

    Asset C

    $1,200,000

    $1,200,000

    $300,000

    $200,000

    The fund wishes to defer the liability for these capital gains, so it calculates a ‘deferred notional gain’ for each asset by applying the 2016–17 exempt proportion to the discounted capital gains to determine the portion that would not be exempt:

    • Asset A – deferred notional gain = $300,000 × 15% = $45,000
    • Asset B – deferred notional gain = $60,000 × 15% = $9,000
    • Asset C – deferred notional gain = $200,000 × 15% = $30,000
    • Total = $84,000

    In the CGT Schedule to its 2016–17 Self-managed superannuation fund annual return, the fund selects ‘Yes’ at label 8F – Have you chosen to apply the transitional CGT relief for superannuation funds?’, and includes $84,000 at label 8G – ‘Notional capital gain amount deferred’. The fund needs to keep records of the new cost bases of its assets so that it can calculate its capital gains tax correctly when assets are sold.

    End of example

    Funds that are ‘100% in pension phase’

    A fund is ‘100% in pension phase’ if 100% of the fund’s assets are supporting account-based income streams. In these cases, the assets meet the definition of segregated current pension assets. If a fund was ‘100% in pension phase’ during the pre-commencement period, and its members commuted amounts to the accumulation phase to prepare for the transfer balance cap, CGT relief may be available.

    If the fund transferred specific assets to support these new amounts in the accumulation phase the CGT relief is available for those assets provided the other eligibility criteria were met.

    Alternatively, the fund may have chosen to adopt the proportionate method from that date. In this instance all of the fund’s assets ceased to be segregated current pension assets from that date, and so all assets are potentially eligible for CGT relief. The law does not restrict CGT relief to a particular value or asset in these situations.

    What if the fund received a contribution during the pre-commencement period?

    The contribution formed part of a new accumulation phase account for that member, as contributions cannot be added to existing income streams. This means that the fund stopped being ‘100% in pension phase’ from the date the contribution was received.

    If the fund has clearly documented that it continued to set aside certain assets after it received the contribution, those assets can continue to be segregated current pension assets until a later date. The fund may then be able to access CGT relief if they subsequently switched to the proportionate method later in the pre-commencement period.

    If there is no evidence of a decision to remain segregated, the assets ceased to be segregated current pension assets on the date of the contribution. CGT relief may be available on that date provided the other eligibility criteria are met.

    Example:

    John and Lucy are the members and trustees of their SMSF, the JL SMSF. The JL SMSF has the following assets and members interests at 9 November 2016.

    Member Interests at 9 November 2016

    Interest

    Value

    John – Account Based Pension

    $1,800,000

    Lucy – Account Based Pension

    $1,200,000

    Fund Assets at 9 November 2016 (segregated)

    Name

    Cost Base

    Market Value

    Asset A

    $1,400,000

    $2,000,000

    Asset B

    $600,000

    $800,000

    Cash

    N/A

    $200,000

    As the only interests in the JL SMSF are supporting account based pensions (that is, it is ‘100% in pension phase’), the fund’s assets meet the definition of segregated current pension assets. In other words, the fund is deemed to be using the segregated method for the purposes of its exempt current pension income.

    On 2 March 2017, Lucy makes a $300,000 non-concessional contribution to the JL SMSF. The contribution is held in an accumulation account for Lucy. At this point, the fund is no longer ‘100% in pension phase’ and the fund’s assets no longer automatically treated as segregated current pension assets.

    The fund has two options:

    • Option A – The fund documents that it has specifically identified Asset A, Asset B and the $200,000 cash that was already in the fund to treat as segregated to support John and Lucy’s Account Based Pensions. This requires the fund to hold the $300,000 contribution separately. In this case, the fund’s assets may continue being segregated current pension assets until a later date.
    • Option B – The fund does not specifically identify assets to support the Account Based Pensions. This will mean the assets will cease to be segregated current pension assets on 2 March 2017, and the fund will instead adopt the proportionate method from this date to calculate its exempt current pension income.

    The JL SMSF chooses Option B and on 2 March 2017 it switches to the proportionate method. On 2 March 2017 the fund’s member interests and assets are now as follows:

    Member Interests at 2 March 2017

    Interest

    Value

    John – Account Based Pension

    $1,836,000

    Lucy – Account Based Pension

    $1,224,000

    Lucy – Accumulation

    $300,000

     Fund Assets at 2 March 2017 (~91% exempt)

    Name

    Cost Base

    Market Value

    Asset A

    $1,400,000

    $2,050,000

    Asset B

    $600,000

    $810,000

    Cash

    N/A

    $500,000

    CGT relief is available for Assets A and B as:

    • the fund meets the object of the CGT relief provisions because John needs to commute amounts out of retirement phase to avoid exceeding the transfer balance cap. John does not need to make this commutation until 30 June 2017, but this does not prevent CGT relief from being available
    • the assets meet the eligibility criteria for CGT relief because
      • the assets were segregated current pension assets on 9 November 2016
      • the assets ceased being segregated current pension assets on 2 March 2017 (which is within the pre-commencement period)
      • the fund held the assets for the entire pre-commencement period.

    The fund elects to apply CGT relief to Assets A and B, resetting their cost bases to their market values on 2 March 2017. Capital gains arising out of the application of CGT relief are disregarded, as Assets A and B were segregated current pension assets when the deemed sale for CGT relief occurred.

    As the fund uses the proportionate method for the remainder of the 2016–17 year, a proportion of its earnings from all of its assets will be subject to tax, and the fund will need an actuarial certificate to support its claim for ECPI in this period.

    In the CGT Schedule to its 2016–17 Self-managed superannuation fund annual return, the fund selects ‘Yes’ at label 8F – Have you chosen to apply the transitional CGT relief for superannuation funds?’. The fund needs to keep records of the new cost bases of its assets so that it can calculate its capital gains tax correctly when those assets are sold.

    End of example

    Effect of applying CGT relief

    The deemed sale when CGT relief is applied creates a capital gains event for that asset, and when the assed is deemed to be repurchased it has the effect of being a new asset for CGT purposes.

    This means you will need to hold the asset for at least 12 months after this time to qualify for the CGT discount. Also, the indexation method for assets originally acquired before 21 September 1999 will no longer be available.

    The deemed sale and repurchase only has consequences for capital gains tax – it is not considered an acquisition of an asset for any other purpose (such as the superannuation regulatory consequences of acquiring assets from a related party).

    For assets like shares or units, CGT relief can apply at the parcel-to-parcel level, meaning the trustee can choose which particular shares in an overall holding to reset the cost base for. Note that for unit trusts, CGT relief applies to the units, and not the underlying assets held by the trust.

    Making a CGT relief election

    CGT relief is not automatic; it must be chosen by a trustee for a CGT asset. If CGT relief is chosen, the trustee will need to advise us using the approved form by completing the CGT schedule to the 2016–17 SMSF annual return on or before, the day they are required to lodge. The lodgement date for 2016–17 SMSF annual return has been extended to 30 June 2018 for all SMSFs. This means trustees have until 30 June 2018 to lodge a return with an election for CGT relief, or amend a previously-lodged return in order to include an election if you hadn’t made it previously.

    You need to keep appropriate records for each asset subject to the CGT relief and any deferred tax liability in accordance with your record keeping requirements.

    How do I make the choice?

    If you choose to apply transitional CGT relief to an asset, this creates a deemed 2016–17 CGT event. You:

    • must answer ‘Yes’ at label G 'Did you have a capital gains tax (CGT) event during the year?' (Section B: Income, Question 11 label G) in the Self-managed superannuation fund annual return 2017
    • must indicate on the 2017 CGT Schedule that you are choosing to apply CGT relief
    • may need to include the amount of the resulting capital gain or loss on the 2016–17 SMSF annual return and the 2017 CGT schedule.

    To report the CGT relief election into the CGT schedule you will need to complete the following fields:

    • the election to apply for CGT relief (Question 8 label F)
    • any deferred amount (Question 8 label G).

    It is important to note that this means that many funds who would not currently expect to complete the CGT schedule will need to do so if they wish to make an election to defer the CGT.

    Making a choice is final

    Once you have chosen to apply the CGT relief, the decision is not able to be revoked. If you lodged the 2016–17 SMSF annual return without making the election, you can amend the return within the time limits to make it. However you cannot amend to reverse the election once it has been made.

    To find out more on transitional CGT relief, refer to LCG 2016/8 Superannuation reform: transitional CGT relief for complying superannuation funds and pooled superannuation trusts

    To find out more on how to make the choice in lodging your 2016–17 SMSF annual return, refer to Self-managed superannuation fund annual return instructions 2017.

    See also:

    • Claiming ECPI
    • Transfer balance cap (including what counts towards your cap)
    • LCG 2016/8 Superannuation reform: transitional CGT relief for complying superannuation funds and pooled superannuation trusts
    • LCG 2016/9 Superannuation reform: transfer balance cap
    • LCG 2016/10 Superannuation reform: defined benefit income streams – non-commutable, lifetime pensions and lifetime annuities
    • LCG 2017/1 Superannuation reform: defined benefit income streams – pensions or annuities paid from non-commutable, life expectancy or market-linked products
    Last modified: 14 Feb 2018QC 51874