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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.
