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Division 296 — Alternative Investment Optimiser | SMSF Alliance

Division 296 — Alternative Investment Optimiser

Purpose of This Model

Div 296 tax law applies from 1 July 2026. It will target those super fund members with over $3m in total super balances as at 30 June 2027. Members wishing to avoid the tax entirely will need to reduce their total super balance by 30 June 2027. Undoubtedly the imposition of Div 296 tax will decrease the tax advantages of superannuation to in scope members but simply withdrawing from super to avoid the tax, without considering the consequences of investing in alternative investment scenarios, is not prudent. If the action taken to avoid paying Div 296 tax results in a greater reduction in the member's wealth than if Div 296 tax was simply paid, then perhaps the best course is to take no action at all.

This tool compares the total wealth outcome of holding assets primarily within superannuation versus withdrawing a portion and investing it through a non-super vehicle — as an Individual, a Company, an Insurance Bond, or a Discretionary Trust. All four structures are modelled simultaneously against the same super baseline. The question it addresses is: "After accounting for the different costs and tax treatments of each vehicle, the Div 296 tax I avoid by reducing my super balance, and the different growth profile of each structure, which combination of super and non-super vehicle produces the highest total wealth over time, if any?"

To isolate the structural comparison, this model assumes that pension payments leave the system. Minimum pension payments are drawn from the super fund and paid to the member — they are not reinvested into the alternative vehicle. The alternative vehicle’s balance is determined solely by the initial lump sum withdrawal and its subsequent investment returns. Alternative results are compared against the superannuation baseline which assumes that no withdrawals are made to lower the member's total super balance.

Important: Because the legislation uses realised earnings (not unrealised gains) as the Div 296 base, the result is highly sensitive to the income yield vs capital growth split. We have provided several investment portfolio types for you to compare.

The cost of redeeming investments, both transaction and capital gains tax costs, will reduce the desirability of liquidating superannuation investments, as does any cost on investing in the alternative structure. This is highly relevant and can materially alter the comparative outcome as the alternative structure's investment scenario starting point, considering both the fee and tax reduction to super and the cost of investing in the alternative structure, will be less than the amount withdrawn. Note that after considering the initial cost of adjusting the member's investments, transaction costs for all scenarios are assumed to be nil.

We ask for cost base details on the member's existing super investments. This is for the calculation of capital gains tax on assets that need to be redeemed plus capital gains tax on future redemptions, until they have been replaced by investment turnover. For Div 296 purposes, SMSF investments will have a frozen cost base at 30 June 2026. APRA-regulated funds — both Pooled (e.g. industry funds) and Non-Pooled (e.g. super wraps) — use a different Div 296 method: a transitional inclusion factor applied to the full realised gain rather than a frozen cost base. The model switches to that treatment if you select either APRA Source Fund Type. CGT treatment on member redemptions differs between the two APRA variants: Pooled APRA pools CGT across all members through unit pricing (no member-specific CGT), whereas Non-Pooled APRA uses the same member-level CGT treatment as an SMSF because the fund operates as segregated pension + accumulation sub-funds at the member level. Treasury's position is that long-term Division 296 outcomes for the three fund types should be broadly comparable.

Planning Aid Only

This modelling tool is provided by SMSF Alliance as a public service. Results are scenario-based projections and do not constitute financial advice. SMSF Alliance accepts no responsibility for the way this tool is used. Actual outcomes will depend on investment performance, legislative changes, and individual circumstances. Division 296 calculations reflect the Treasury Laws Amendment (Building a Stronger and Fairer Super System) Act 2026 as passed 10 March 2026, using the realised-earnings methodology.

Model Inputs

Updated for the 2026–27 Federal Budget. This model now incorporates the replacement of the 50% CGT discount (effective 1 July 2027) for individuals and trusts: only the part of the gain that exceeds inflation is taxable, at the higher of your own rate or 30%. It also incorporates the 30% non-refundable minimum tax on discretionary trust income (effective 1 July 2028). Super treatment is unchanged.
Getting started. Most fields are pre-filled with sensible defaults, so only a handful of inputs actually need your attention before running the model. Fields flagged Required have no default and must be filled in: name, date of birth, pension balance, and accumulation balance. Fields flagged Check default already have a value but the choice materially affects the result — review the fund type, the CPI rate, and (for an SMSF) the portfolio cost base and the cash held in the fund. Everything else can be left as-is for a first pass.

Member Details

Used for report labelling.
Member's age on 1 July 2026 (start of the projection). Range 59–85: a 59-year-old turns 60 during the FY2026-27 projection year (meeting condition of release), and 85 leaves at least the minimum 5-year projection to age 90. Drives minimum pension draw rates and the projection end (age 90).

Source Fund Type

Default is "SMSF or small APRA-regulated fund" (six or fewer members), where Division 296 uses the frozen cost base at 30 June 2026. "Pooled APRA-regulated fund" (e.g. industry funds) uses the transitional inclusion factor on realised capital gains and deducts an investment management fee; no member-specific CGT on withdrawal because redemptions are unit-price-based. "Non-Pooled APRA-regulated fund" (e.g. super wraps) uses the same Div 296 treatment as Pooled APRA in ongoing years, but at Year 1 it operates as segregated pension + accumulation sub-funds: the withdrawal is sourced pension-first (ECPI, zero CGT) with any shortfall drawn from accumulation at 10% effective on gain.

Member's Superannuation Balances (at 30 June 2027)

Pension account balance at 30 June 2027, after pension draw and 2026-27 investment returns.
Accumulation account balance at 30 June 2027, before any withdrawal under this strategy.
The fund's actual tax cost base as a percentage of current market value. Used for CGT on asset sales and portfolio turnover. A lower percentage means larger embedded unrealised gains.
The same fund's actual tax cost base as a dollar value. Editing either field automatically updates the other.

Year 1 Transaction Costs

Cash already held in the fund. Up to this amount of any calculated withdrawal can be met from cash rather than by selling assets — so no CGT or sell-side cost applies to that portion. Capped by the optimiser at the calculated withdrawal amount.
Year 1 only. Transaction costs on asset sales within the fund (brokerage, agent fees, legal). Reduces fund balance and capital gain. Typical ranges: listed securities 0.1–0.3%, managed funds 0%, direct property 2–5%.
Year 1 only. Transaction costs on purchasing assets in the new entity (brokerage, stamp duty). Reduces initial investment. Typical ranges: listed securities 0.1–0.3%, managed funds 0–0.5%, direct property 3–6%.

Annual Costs & CPI

Ongoing annual costs for each vehicle. For SMSF the super-side cost is a flat dollar amount (CPI-indexed). For APRA-regulated funds (Pooled or Non-Pooled) the super-side cost is a percentage of balance — on Pooled APRA this represents the investment management fee only (the flat admin component is immaterial at Division 296 balances and is not modelled separately); on Non-Pooled APRA it is a single combined fee covering platform administration and underlying investment management.
Member's share of total fund costs (admin, audit, actuarial, accounting). Most SMSFs have two members — enter this member's portion only. Applies to both baseline and strategy. Typical range: $1,500–$5,000 per member.
Investment cost charged by the Pooled APRA fund, deducted from the super-side gross return. Typical ranges (PDS disclosures): indexed / passive options 0.10–0.30%, actively-managed diversified options 0.50–1.00%. Default 0.6% is a conservative mid-point for a typical active MySuper / Balanced option; override to match the member's actual option.
Insurance bond admin fees are percentage based and typically range from 0.30–0.70% above the underlying managed fund management expense ratio which is already reflected in the return parameters used.
Additional accounting cost for investment income in personal tax return. Typical range: $500–$2,000.
Tax return, ASIC fees, registered office, governance. The same default applies to both vehicle types. Typical range: $3,000–$6,000.
Default is 3.00% — the 10-year Australian CPI average (2016–2025). CPI flows through several parts of the model: it indexes the Div 296 $3M and $10M thresholds (higher CPI = less Div 296 tax over time), it indexes the personal marginal-rate brackets, it indexes the cost base used for individual capital gains under the post-budget regime from FY 2027-28 (higher CPI = lower real gain and less tax), and it uplifts external income year-on-year. The result is moderately sensitive to this assumption — consider whether your own long-run inflation expectation differs.
Fixed rate applies a single rate (including Medicare levy) to all entity income and capital gains. Marginal rates use the 2027-28 personal tax brackets (CPI-indexed) and account for external income to determine the member's actual marginal rate.
The member's other net taxable income (salary, rental, business, etc.) in 2026-27 — used to determine the starting marginal tax bracket. This income is CPI-indexed over the projection but does not form part of the model's wealth calculations.

Portfolio & Return Assumptions

Select a profile to pre-fill return, income/growth split, and turnover. Choose "Custom" to set your own values. Changing the preset overwrites the fields below — you can still fine-tune them afterwards.
Default set by the portfolio profile selected above. Can be overridden.
Default set by the portfolio profile. Capital growth = Gross Return minus Income Yield.
Default set by the portfolio profile. Fraction of portfolio sold annually, triggering realised capital gains.
Proportion of income yield that carries franking credits. Default set by the portfolio profile. 0% for unfranked income (international, property, cash, bonds).

SMSF Alliance

This tool is a planning aid only. Results are scenario-based projections and do not constitute financial advice.

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