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Meg on SMSFs: watch traps in EOFY contributions

In a monthly column to assist trustees, specialist Meg Heffron explores major issues on managing your SMSF.

As Liam Shorte said in his excellent article here, there are so many things worth doing at the end of the financial year that we almost need an extra month to do them.

But one of Liam’s suggestions (Item 9) caught my eye as being worthy of more discussion: claiming tax deductions for personal super contributions. The article highlights the importance of putting in the right paperwork at the right time, which is absolutely crucial. There are a number of points that are often forgotten.

Eligibility for and use of a deduction 

Anyone aged between 18 and 67 is eligible to claim a tax deduction for their personal contributions as long as they have enough income to do so (you can’t use one of these tax deductions to create a tax loss). It doesn’t matter how the income was earned in the first place or whether the person is working. 

Working is only important for people over 67. Someone between 67 and 75 who does meet the relevant work test, though, can also claim deductions for their super contributions. For this purpose, the work test is doing paid work for at least 40 hours in a 30-day period at some point before 30 June 2023. It doesn’t need to be met before the contribution was made.

And the deductions can be useful for all sorts of people at different stages of life, for example:

1. Someone who is 60 and retired but made a large (personal) capital gain. The deduction will help reduce the tax they pay on that capital gain.

2. Or perhaps they’re 20 and at university but received a distribution from their parents’ family trust. The deduction will reduce the tax they pay on that distribution.

3. Or working and just didn’t get around to putting a salary sacrifice arrangement in place and have some spare cash they’d like to put into super in the next two weeks.

All of these are scenarios where a tax deductible super contribution could be very handy.

The limit

These contributions (together with any contributions made by an employer) are checked against the member’s 'concessional contributions cap'. For most people this is $27,500 but as Liam points out in his article (Item 3) some people can also use limits they haven’t used in the past.

Watch for the traps

There are a few traps that can easily bring a good strategy undone and it’s largely to do with the paperwork. Liam’s article touched on two – it’s critical to prepare and sign the paperwork before starting a pension or taking money out of the fund.

1. Starting a pension

There are some quirky rules around these contributions that mean if you (say):

  • contribute to your fund in July 2022,
  • start a pension with even just some of that super account in December 2022, and then
  • complete the paperwork for your tax deduction in July 2023,

your deduction is denied. You have to do the paperwork before starting the pension.

What if it’s too late and you’ve only just discovered that this is how things work and haven’t done your paperwork yet?

That’s terminal for your July contribution but you could make another contribution now (June 2023) as long as the paperwork is completed before doing anything with this money (such as starting another pension or making a withdrawal).

What that will mean is that your July 2022 contribution has to be treated as a non-concessional contribution.

What if you weren’t actually able to make these types of contributions in 2022/23? People who had too much in super at 30 June 2022 or who had already used up their 2022/23 cap for these contributions beforehand would be in this boat.

Don’t panic, it’s not illegal to do that. It just means you’ll have an 'excess' non-concessional contribution. The ATO will issue a notice telling you about it in due course and unless you really want to leave it in your fund (don’t do this), your fund will eventually be told to refund it to the ATO, together with some interest.

The ATO will use that as an opportunity to grab any money you already owe them (if you have outstanding personal tax bills) but will give the rest back to you less some tax on the interest. It’s not a terrible result and will at least mean you get to claim the tax deduction you were aiming for.

2. Taking money out of the fund

Something similar happens if you’ve taken your money out of your super fund during the year after making the contribution but before doing this paperwork. Unfortunately the deduction gets 'scaled back' – if you took 25% of your super balance out of the fund, you can only claim a deduction for 75% of the contribution. In fact, if you took all your money out of your fund you’d get no tax deduction at all. That even happens if you just moved your super from one fund to another. Ouch.

3. Changing your mind

What if you planned to claim a tax deduction for $20,000 and put this paperwork in place in July 2023? Then in October 2023 – while doing your personal tax return – you realise you actually have more income than you thought. You’d really like to increase your deduction.

Unfortunately, you can’t change a notice you’ve already done to increase the deduction you claim. (You can vary it down, even to $nil, but not up.)

A tip for the future is that if you make multiple contributions in a particular year, your deduction can be attached to specific contributions. In this case, let’s imagine you contributed $20,000 in August 2022 and $15,000 in May 2023. Your original plan was that the May amount would be a non-concessional contribution. You haven’t started a pension or taken any money out of the fund during 2022/23.

If your notice about claiming a tax deduction was specifically attached to the August 2022 contribution, there’s nothing to stop you doing another notice later to claim part of the May contribution as a personal tax deduction. That second notice could even happen in October when you discovered the problem.

In other words, you can do as many notices as you like (one for each contribution in the extreme) and they can be specifically attached to individual contribution amounts rather than just “all the contributions made this year”.

4. And finally on the paperwork

There are two components to these notices. The member tells the trustee they intend to claim a tax deduction (and which contributions it relates to) and then the trustee acknowledges it. Both components are critical. The tax deduction isn’t valid without them. And this is one time when the date it’s actually signed is critical.

This is quite different to other SMSF events. For example, it’s common for pensions to start on 1 July but for the paperwork to be formally signed some time later. That can’t happen for these notices. They have to be actually signed before the earlier of:

  • the date the member lodges their personal tax return for the year, or
  • 30 June of the following year (so 30 June 2024 for 2022/23 contributions).

That means someone who lodges their 2022/23 tax return on 15 October 2023 has until 14 October 2023 to do this paperwork as long as they don’t start pensions etc beforehand.

Claiming a tax deduction for super contribution can be a great strategy and definitely something to consider before 30 June. But this is definitely one time when the paperwork really matters.

 

Meg Heffron is the Managing Director of Heffron SMSF Solutions, a sponsor of Firstlinks. This is general information only and it does not constitute any recommendation or advice. It does not consider any personal circumstances and is based on an understanding of relevant rules and legislation at the time of writing.

For more articles and papers from Heffron, please click here.

 

12 Comments
Trevor Wickham
July 18, 2023

Hi Meg, late comment. My wife and I are looking at transiting to pension phase in the second half of this FY 23/24. I turn 64 in March 2024 and my wife turns 60 in December 2023. We are living comfortably of current investment income and would like to start drawing down on our Superannuation as the additional tax-free income will allow us to assist with our grandchildren’s private schooling. Over the past 2 x FY 21/22 & 22/23 we have contributed $110k non-concessional to my wife’s super with a view of contributing $330k this FY 23/24 prior to transiting to pension phase in early 2024. Our respective Super balances as at 30 June 2023 is: Me: $1,800,000, wife: $700,000. I won’t be making any non-concessional contributions this FY as i used up my 3 year bring forward in FY 22/23, but wanted to make sure that we can take advantage of the 3 year bring forward rule and make a $330k non-concessional contribution to my wife’s super balance. Do you foresee any issues with this approach? Thanks.

Meg Heffron
July 18, 2023

Hi Trevor, assuming you're purely asking me about the rules rather than whether or not this is a good idea (I have to be careful not to stray into giving advice here) - anyone under 75, with a total super balance of less than $1.68m at 30 June 2023 who isn't already in the middle of a 2 or 3 year bring forward period as a result of past contributions can use the bring forward rules in 2023/24 to contribute $330k. The thing to watch for given your wife's balance is just make absolutely sure she hasn't gone over the $110k cap by accident in previous years, even by as little as 1c. That might sound like an easy thing to check but the things that catch people out sometimes are when they pay a bill for the super fund and don't reimburse themselves - that will get treated as a non-concessional contribution. If your wife contributed - say - $111k in 2022/23 she will have triggered the "$330k over 3 years" last year and that $115k will have used up some of it.

Meg Heffron
June 17, 2023

Ruth - if you turn 67 in September 2023 you could make concessional contributions in BOTH (say) June 2023 (for the 2022/23 financial year) and July 2023 (for the 2023/24 financial year) without needing to meet a work test. If you make the second contribution after your birthday (say October 2023 for the 2023/24 financial year), you'd need to meet the work test. I think that's what you're asking? I know you mention 1 July 2024 above but I think you mean 1 July 2023.

Graeme
June 15, 2023

One comment and one query.
Re 'Changing your mind'. I've always waited until I've received the last of my managed investment trust tax statements (often late September) and almost completed my tax return before submitting a deductible contribution notice. This way there are no surprises and I can claim exactly the amount I need, in my case to avoid entering a higher tax bracket.
I turn 67 in a month's time (not working) and hence can make a final deductible contribution prior to that date. Can I still delay sending a deductible contribution notice in, or is there a special rule that requires having the notice and acknowledgement completed before I turn 67?

Meg Heffron
June 15, 2023

To answer your question first : no, there's nothing special about turning 67 that impacts the timing of notices. All that's important (given you've retired) is actually making the contribution before your birthday. In fact you have an opportunity to it all again in 2023/24 given that you'll actually turn 67 in July.
In terms of the timing of your notice - leaving it until you do your tax return is perfectly fine. Sometimes the reason people bring their notices forward (and do them on 30 June) is because they want to start a pension on 1 July / withdraw some money early in the new year or want to split the contributions with their spouse as early as possible in the new year (and you can't do this until you've "turned them into concessional contributions" by doing this paperwork). Otherwise, I'm with you, leave the notice until you do your tax return.

Barry
June 18, 2023

Hi Meg,

Why do you recommend that we don't leave the excess contribution in the super fund? Can you explain the reasoning behind that?

I intend to keep the excess contribution in the fund because my SMSF has an old trust deed from 2008 which may not allow releasing money from the SMSF so I don’t want to do something that the trust deed does not allow.

My situation is age 46, less than $1.7 million TSB on 30th June 2021 and more than $1.7 million TSB on 30th June 2022, so able to make non-concessional distributions during FY2022. In June 2022 I got an unexpected pay rise at my employer and they paid more concessional contributions into my super than I was planning to get during FY2022 and the total concessional contributions went over the concessional limit by about $100.

So my understanding is that the ATO will send me a letter and give me the option to turn the excess concessional contribution into a non-concessional contribution and I want to accept that option and keep it in the super and I want to pay any extra tax from my own personal resources not from the SMSF.

What I’m unclear about is do I report the excess contribution as a concessional contribution in the SMSF AR so that the ATO will pick up on it and send me a letter but then after the concessional contribution becomes a non-concessional contribution, do I then have to reclassify this excess amount in BGL360 so that it is treated as a non-concessional contribution in the member statement in future years?

Dudley
June 19, 2023

"my SMSF has an old trust deed from 2008 which may not allow releasing money":

If the old trust deed allows changing the trust deed then amend / abolish the rule(s) that are troublesome.

Trust deeds are silly old fudy duddy tattered rags that are subordinate to the SIS Act rules. Seems no one can find enough energy organise their abolition.

Meg Heffron
June 24, 2023

Hi Barry, it's perfectly legal to leave yours in the fund. And you just report all concessional contributions, including the amount that you know is going to put you over your cap, in the usual way. There is no extra reporting - the ATO will work out that it's over your concessional cap and will count it towards your non-concessional cap if you don't take it out (and instead pay the extra tax from your own resources). You don't re-classify the excess as a non-concessional at your end (in fact you can't - it remains a concessional contribution in every sense except that it counts for your non-concessional cap). The main downside of doing this is generally mild. It's the fact that the excess amount remains part of your taxable component even though it counted for your non-concessional cap. My "don't do this" comment was for people who were also over their non-concessional cap - leaving it in the fund under that circumstance would mean it gets hit with an extra tax again. There are only very rare circumstances where that's attractive.

Barry
June 24, 2023

Thank you for that Meg. Very useful information.

Gary Bowtell
June 15, 2023

Thankyou Meg. Very informative.
Just wondering - if you complete the Intention to claim a deduction for the contribution to a SMSF, is there any time limit on when the contribution has to be made. For example could you complete the form on 1 July 2023 but not make the contribution/s until June 2024 ( and via a number of contentions on different dates in June).

Meg Heffron
June 15, 2023

Hi Gary, the notice has to come after the contributions. So you could make the contributions in June 2024 and do the notice pretty much any time up until you do your 2023/24 income tax return (say October 2024 or even May 2025)

Ruth
June 17, 2023

Meg, I have wondered about this. If you turn 67 in a calendar year, say September 2023, does this mean that even though you have made a concessional contribution into super for the 2023 financial year, that you can make another concessional contribution in that same calendar year (say 1 July 2024) for the 2024 financial year before you turn 68 in September 2024. I really don't know why I'm asking; it is clear to me that they will stop at nothing to milk every cent you have before you reach retirement and the system is ridiculously complex already, to the point that I believe the young will request that their wages don't go into super at all, as they will wake up that they many never see their savings after so many rule changes.

 

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