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Tax Planning

Division 296: Managing Super for High Balance Individuals

If your total super balance exceeds $3m (or $10m), new Division 296 rules from 1 July 2026 may cost you tax on earnings above those thresholds—understand what applies and how to plan ahead.

By NomadicTax Research Team · 5-6 min read

Overview of Division 296

From 1 July 2026, new rules introduced in Division 296 affect individuals with Total Super Balances (TSB) exceeding the Large Super Balance Threshold (LSBT) of $3 million and Very Large Super Balance Threshold (VLSBT) of $10 million. Only the earnings linked to the portion of your super balance above these thresholds are taxed differently. (community.ato.gov.au)

How the Tax Applies

ScenarioSuper balance at year-endTax on earnings above threshold
Between $0 and $3mBelow or equal to LSBTNo change—normal earnings tax in super fund applies
Above $3m (up to $10m)Earnings portion above LSBT15% tax on earnings above $3m threshold
Above $10mEarnings portion above VLSBTAlways taxed 25% on earnings above $10m (15% + extra 10%)

Note: TSB is checked both just before and at year-end; the greater determines threshold‐crossing. Earnings aren’t taxed until the fund reports them and ATO issues Notice of Assessment (expected in late 2027-28 for 2026-27 year). (community.ato.gov.au)

Planning Considerations for High Balance Super Members

  • Investment strategy: If part of your super is invested in high yield assets, earnings above the thresholds will be taxed more heavily. Consider asset types and expected returns.

  • Timing of contributions / withdrawals: While threshold is measured at year-end (and near start), managing contributions timing cannot avoid tax but might affect whether the earnings are caught.

  • Fund structure: For those with multiple funds, ensure total balances are consolidated or well understood so matching the threshold interacts across funds.

  • Reporting readiness: SMSF members and APRA regulated funds both report earnings over thresholds to ATO; you may need to provide information to trustees or fund managers. (community.ato.gov.au)

Practical Example

“Jane” has a TSB of $4 million at 30 June 2027. For that financial year:

  • Earnings on first $3 million taxed as normal in fund (say 15%).
  • Earnings on the $1 million above $3 million taxed at 15% under Division 296 (no extra if under $10m). If TSB had risen above $10 million, earnings above that point would be taxed at 25%.

Her fund reports earnings; she receives Notice of Assessment in late 2027-28. She cannot avoid tax on those earnings over thresholds, but knowing this can guide future investment allocations.

Actionable Steps

  • Monitor your TSB regularly—even mid-year forecasts help with planning.
  • Ask your super fund for projected earnings so you can estimate extra tax.
  • If high risk of exceeding thresholds in future, diversify funds or adjust asset allocation with expect yield and tax rate in mind.
  • Stay updated on threshold indexing—LSBT and VLSBT may increase in line with CPI or similar. (community.ato.gov.au)

Conclusion

Division 296 introduces a “new tax layer” for earnings linked to super balances above $3m and $10m, effective from 1 July 2026. While the rules don’t affect all super members, those with high balances should assess their investment mix, fund structure, and stay ahead of reporting responsibilities to manage after-tax returns effectively.

Sources

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