Division 296 Tax – Key Revisions Announced

The Federal Government has announced several important refinements to the proposed Division 296 tax, designed to ensure a fairer and more practical approach to taxing large super balances.

Key Changes

  • Applies to realised earnings only — unrealised gains will no longer be taxed.
  • $3 million threshold indexed to CPI in $150,000 increments, aligned with the Transfer Balance Cap.
  • New $10 million threshold introduced, with earnings above this level taxed at 40% (compared to 30% between $3-10 million).
  • Start date deferred to 1 July 2026.
  • Defined benefit pensions included, ensuring consistent treatment across super structures.

Effective Tax Rates

  • Up to $3 million: 15%
  • $3–10 million: 30% (15% standard + 15% additional)
  • Above $10 million: 40% (15% standard + 25% additional)

How the ATO Will Apply the Tax

Super funds will continue to report members’ balances to the ATO, which will:

  1. Identify members with balances over the thresholds.
  2. Request realised earnings data from their fund.
  3. Calculate and issue the additional tax liability.

Earnings attribution will be based on existing reporting systems and ATO guidance to ensure fairness.

Illustrative Examples

  • Megan: $4.5m balance, $300k earnings → $15,000 additional tax
  • Emma: $12.9m balance, $840k earnings → $115,581 additional tax

If you have any queries that you would like to discuss with us, please feel free to contact your client manager.