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T Assessable income due to changed tax status of fund

Last updated 12 February 2019

Show at T the amount that is to be included in the fund’s assessable income as a result of a change in tax status of the fund.

A fund that changes from complying to non-complying, or a fund that was not an Australian superannuation fund but becomes an Australian superannuation fund, must calculate the amount of ordinary income and statutory income from previous years and include these amounts in the assessable income of the fund in the year the status of the fund changed.

A change in compliance or residency status for a fund may result in changes in tax rates which apply to the taxable income of the fund.

The fund became a non-complying fund during the year

If during the income year the fund changed from being a complying superannuation fund to a non-complying superannuation fund, the fund’s assessable income for that income year includes its ordinary income and its statutory income from previous years, as calculated using formula A below.

In effect, the fund loses the benefit of tax concessions that it obtained as a complying superannuation fund.

Formula A

Asset value – non-concessional contributions = assessable amount

where:

  • asset value is the sum of the market values of the fund’s assets immediately before the start of the income year in which the fund became non-complying, and
  • non-concessional contributions (formerly referred to as ‘undeducted contributions’) is the sum of
    • the part of the crystallised undeducted contributions that relate to the period after 30 June 1983, and
    • the contributions segment for current members that have not been, and cannot be, deducted.
     

Show at the amount calculated using formula A for the income year in which the fund became a non-complying fund. That amount is taxed at the rate of 45%.

The fund was, but no longer is, a foreign fund

If a fund was a foreign superannuation fund and became an Australian superannuation fund for the income year, its assessable income for that income year includes the amount calculated using formula B below:

Formula B

Asset value – member contributions = assessable amount

where:

  • asset value is the sum of the market values of the fund’s assets immediately before the start of the income year in which the fund became an Australian superannuation fund, and
  • member contributions is the total amount of current member contributions in the fund at the time.

Show at the amount calculated using formula B.

When a fund changes status from a foreign superannuation fund to a:

  • complying Australian superannuation fund, the amount is taxed at the rate of 15%
  • non-complying Australian superannuation fund, the amount is taxed at the rate of 45%.

The fund is not entitled to a tax offset for the foreign income tax that was paid in the previous year if:

  • a previously complying fund or a previously foreign fund includes an amount in assessable income under either formula A or formula B above, and
  • the trustee of the fund paid foreign income tax in respect of that amount before the start of the income year.

QC35420