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How super members can avoid missing out on tax deductions

Claiming a deduction for personal super contributions can reduce personal tax and increase retirement savings, but there are many traps for the unwary.

Misunderstanding the eligibility rules can mean a member isn’t able to claim all (or even any) of the contribution(s) as a tax deduction.

In this article, we explain the requirements for being able to successfully claim a tax deduction for personal super contributions.

Notice of intent to claim

To claim a tax deduction for personal super contributions, a member needs to submit a valid notice of intent to claim a tax deduction to the trustee of the fund. The notice is often known as a section 290-170 notice, which is the section of the tax law that covers deductible contributions. The form is available on the Australian Taxation Office (ATO) website - NAT 71121.

General conditions

Conditions for claiming a tax deduction for personal contributions include:

  • the individual is still a member of the super fund at the time of lodging the notice
  • the relevant contributions are retained within the fund (ie they haven’t been partially or fully withdrawn or rolled over from the fund)
  • the trustee hasn’t begun to pay a pension based in whole or part of these contributions
  • the member hasn’t supplied a super splitting notice to the fund in respect of the same financial year
  • no part of the contribution(s) are covered by an earlier notice, and
  • the member has received a notice of acknowledgement from the trustee of the super fund.

Timeframes

The notice of intent to claim a tax deduction must be submitted on or before the first of the following dates:

  • the date the member submitted their tax return, and
  • 30 June of the following financial year after the member made the contribution(s).

Work test

Members who are age 67 to 74 at the time the contribution is made need to meet the work test in the financial year in which the contribution is made. To meet the work test, the member needs to have worked at least 40 hours over a 30 consecutive day period.

Alternatively, members may be able to use the work test exemption if:

  • their total super balance at the previous 30 June was less than $300,000
  • they met the work test in the previous financial year, and
  • they have never previously used the work test exemption.

Impact of partial withdrawals and rollovers

Where a member makes a partial withdrawal (including a rollover) during the year, part of the withdrawal is defined as including contributions made before the withdrawal. This means that unless a notice of intent to claim a tax deduction is received prior to a withdrawal, the member won’t be able to claim a tax deduction for all of the personal contributions made that year.

A valid notice of intent to claim a tax deduction will be limited to a proportion of the tax-free component of the superannuation interest that remains after the roll over or withdrawal. The proportion is the value of the relevant contribution divided by the tax-free component of the superannuation interest immediately before the partial withdrawal.

The tax-free component of the withdrawal is:

The tax-free component of the remaining interest is:

The remaining amount of the personal contribution is:

Some members use regular rollovers to fund insurance premiums in an insurance only super fund. In some instances, members may not be fully aware of the impact on their ability to claim a tax deduction, as the case study below illustrates.

Case study

Chai contributes $2,500 per month to super and intends to claim $30,000 as a tax deduction in 2024/25. On 31 December 2024, Chai rolls over $3,000 to pay for annual insurance premiums in an insurance only super fund. Chai doesn’t provide the super fund with a notice of intent to claim a tax deduction before the rollover.

As at 31 December 2024, Chai’s super balance is $100,000 and the tax-free component is $15,000 (the contributions for which a notice of intent to claim a tax deduction hasn’t been received by the fund).

The tax-free component of the rollover is:

The tax-free component of the remaining interest is:

The remaining amount of the personal contribution is:

Chai contributes a further $15,000 before the next 30 June. Chai then lodges a notice with the intention to claim a deduction for the total of $30,000 contributed in 2024/25. The notice is not valid as the super fund only holds $14,550 of the first half of the year’s personal contributions. Chai can only lodge a valid deduction notice for an amount up to $29,550.

Chai could claim the whole $30,000 by lodging a notice of intent to claim a tax deduction of $15,000 before the rollover occurs, and a second notice for the subsequent $15,000.

Multiple withdrawals

Multiple withdrawals/rollovers further complicate the calculations and further reduce the amount of contributions for which a tax deduction can be claimed. In addition, transactions in the following financial year may reduce the amount available to be claimed.

Conclusion

Understanding the eligibility requirements for claiming a tax deduction for personal contributions will enable members to maximise their tax deductions. The calculations are complex and not necessarily intuitive.

Any members who make partial withdrawals should seek financial advice regarding the amount that can be claimed. However, lodging a notice of intent to claim a tax deduction prior to requesting any partial withdrawal will maximise the amount that can be claimed.

 

Julie Steed is a Senior Technical Services Manager at MLC TechConnect. This article provides general information only and does not consider the circumstances of any individual.

 

17 Comments
mike
July 24, 2024

Hi Julie S and fellow readers.
I have this 'technical' question.
Say I 'converted' my accumulation fund to pension fund in say 18th July 2024. Every cash and shares were made pension fund. I know that tax will be paid on income between 1/7/2024 to 17/7/2024 ( accumulation phase ). Earnings ( interest, dividend, cap gains) post 18th July 2024 is not taxable.
This is the 'trick' question, what if there is a share that was ex div on 15/7/2024 and paid on 30/7/2024. These div and imputation credit, does it belong to accumulation or pension phase ( I know for cap gains/loss for shares, it is the contract date , not the settlement date, that is used ).
Can anyone pls enlightened ?
I thank in advance.

SMSF Trustee
July 24, 2024

Mike, a couple of things as I understand the situation.
1) you don't allocate specific assets to pension and others to accumulation. It's one investment fund with all earnings taxed in proportion to the % of the total is in accumulation vs pension.
2) thus the dividend and franking credit will be in effect split between the two rather than belonging all to one or the other
3) tax operates on date income is received (except capital gains) so it doesn't matter when the ex-date is.

Happy to be corrected by a tax expert if the above is wrong.

mike
July 24, 2024

Hi SMSF Trustee,
Tq for your reply.
I wanted to move away from the proportion formula, so all the assets ( cash and shares ) are made pension, so all balance is in pension mode. There is no assets in the accumulation phase anymore. Clean cut 100% in pension on say 18/7/2024. There will be income that belong to pre pension phase ( aka accumulation phase ) before I make all balance to be pension. Hence I am asking if ex date or payment date of dividend will be used to determine if they belong to accumulation or pension phase. If ex date, then the div belong to accumulation phase, if payment date then for me it is in pension phase.
( my intent is to use another to be opened industry fund super for accumulation phase, to receive personal super contribution , employer super guarantee just in case i do some part time free lance work in future, when down sizing the principal home etc . ).

SMSF Trustee
July 24, 2024

Understand Mike.

I also think that since the pension account is started within a month of the fiscal year starting then it will just be tax free income for 24-25. By same token you'll have to pay the right pension % based on it being in place for a full year. Different starting later in the year.

Jack
July 24, 2024

You will need an actuarial certificate that certifies to the ATO how much of an SMSF’s earnings are derived from its members’ accumulation phase balances and how much from retirement phase balances (pensions). The income will be apportioned between the two because the accumulation fund is taxed but the pension fund is tax exempt. I am not an actuary, but I suspect that the proportions are based on the number of days in each phase, not the date on which the income was received.

mike
July 23, 2024

Hi Julie S and all that have commented on my questions, thank you.
May I ask further questions, without liability nor prejudice.
I have a smsf with balance say $1.9m and in pension phase in July 2024 ( FY 2025 ).
I will make the mandatory withdraway in financial year 2025, 4% of $1.9 = $76000.
Come 30/6/2025, the equity market has been super hot, so that my
Balance of pension fund at 30/6/2025 ( we use market value of shares ) is $4m.
Balance of accumulated fund at industry super say $50k.

1) how would this extra tax on earnings on balance beyond $3m impact me ?
2) is the balance of pension fund disregarded ?
3) come FY 2026, I will need to withdraw minimum 4% on the $4m (balance at 30/6/2025 which is made up of a lot of unrealised capital gain )
4) tq kindly.

Jon Kalkman
July 23, 2024

There are two types of contributions to super. Pre-tax contributions that are not taxed before going into super are then taxed within the super fund. They include the employer’s SG, salary sacrifice and tax deductible personal contributions (after you give Notice of Intent). The total of these contributions must not exceed $30,000 per year. After-tax contributions, such as personal savings, proceeds of the sale of an investment or inheritance are not taxed again inside the super fund. These contributions are limited to $120,000 per year. A super fund in accumulation phase pays tax on these pre-tax contributions and on the income and capital gains of the investment earnings within the fund. The fund continues to grow with new contributions and the reinvestment of earnings. Once in pension phase, there can be no more contributions. The super fund pays no tax on income or capital gains. The amount that can be transferred to a pension account is limited by the Transfer Balance Cap (TBC) and there are also mandatory pensions that must be withdrawn in cash that increase with age. At age 65, the minimum is 5%. At age 90 it is 11%. This ensures the capital in the fund is progressively withdrawn. The member drawing a pension from the fund also pays no tax on that pension. It doesn’t even appear on their personal tax return. In retirement there is no requirement to establish a pension account and any money in excess of the TBC can remain in accumulation phase indefinitely. There is then is no mandatory withdrawal requirement and the accumulation fund can continue to accept contributions but it also continues to pay tax on investment earnings. It can grow until death which is a cash-out event. If you are in pension phase, you may pay no personal tax unless you have income from other sources, so a tax deduction for personal contributions may be of little benefit, but you can continue to make after-tax contributions to an accumulation fund until age 75.

mike
July 21, 2024

Hi Julie S or someone out there in the know, can you comment on this without liability nor prejudice, I just want to know if this can be done....
I have a smsf with balance say $1.9m and in pension phase in July 2024 ( FY 2025 ).
I will make the mandatory withdraway in financial year 2025, 4% of $1.9 = $76000.
I am 65, so none of the $76000 will be taxable.
Can I contribute say $27500 as personal super contribution and give 'Notice to claim as a deduction' in FY 2025 to say UniSuper or REST or Host or any other industry super fund , and claim a deduction in FY 2025 at my personal tax return ?
The legislation is silent on no of hours to be worked for someone age more than 18 yr but below 67 yr.
I am also allowed to have concurrently 1 smsf which is in pension mode and another industry fund ( UniSuper, REST, Host ) which is in accumulation mode ?

Julie Steed
July 22, 2024

Hi Mike,
If a person is under 67 there is no requirement to meet the work test in order to claim a personal deductible contribution. Once a person reaches age 67, in order to claim a deduction for a personal contribution they need to work 40 hours in a 30 day consecutive period in the financial year in which the contribution is made.

There is no limit on the amount of superannuation funds that a person can have. Ordinarily a person can only have one accumulation fund per fund however multiple pensions per fund can be maintained.
Regards
Julie

Jon Kalkman
July 23, 2024

The work test was abolished on 1 July 2022. You can now make personal contributions until age 75. See here. https://www.ato.gov.au/individuals-and-families/super-for-individuals-and-families/super/growing-and-keeping-track-of-your-super/caps-limits-and-tax-on-super-contributions/restrictions-on-voluntary-contributions

Steve
July 21, 2024

Is that personal after tax contribution or pre-tax contribution? Confusing as my understanding is 67+yo can still contribute pretax and salary sacrifice up to 30k pa max without work test applying. Particularly hard to apply work test when earning director fees & technically not an employee. Can anyone clarify?

Graeme
July 22, 2024

From ATO: "If you're between 67 and 74 years old: For the 2020–21 and later years, you must meet the work test (or exemption) to claim a tax deduction for personal contributions and have them treated as concessional contributions".

Steve Gillespie
July 21, 2024

Thanks for the info. However, when accessing the Notice of Intent to Claim Form, the ATO site says:
Do not use this form to claim a deduction for the super contributions that are shown as reportable employer superannuation contributions on your annual payment summary – these are not tax deductible personal contributions.
I'm 56 and still working and have instructed my employer to put in an additional $1000/fortnight before tax, amounting to $26K per year extra. Is this amount considered tax deductible as it is listed in my summary?

Tone def
July 21, 2024

Your extra contributions are called salary sacrifice contributions. You do not pay tax personal income tax on these and hence they are in effect the same as the tax deductable personal super contributions discussed in the article. They fall under the CC (concessional contributions) cap.

Note that the cap for all these contributions is $30K (in FY 2025). Therefore you need to make sure you do not exceed the cap. Your $1000 per fortnight and the 11.5% employer contribution needs to be below $30K when combined. Hence $1000 per fortnight sounds too much and you perhaps need to reduce it.

Istvan
July 22, 2024

Properly explained here: https://www.ato.gov.au/individuals-and-families/super-for-individuals-and-families/super/growing-and-keeping-track-of-your-super/how-to-save-more-in-your-super/salary-sacrificing-super

Julie Steed
July 22, 2024

Hi Steve,
Graeme and Tone def are correct, you don't use the notice of intent to claim salary sacrifice contributions.

Your employer will report them to the super fund (via SuperStream) as concessional contributions, ie pre tax contributions. The super fund will allocate them to your account as concessional contributions when they are received.
Regards
Julie

Jon Kalkman
July 21, 2024

Since 1 July 2022, there is no work test. A member can make personal (after tax) contributions to their super fund until their 75th birthday. The annual cap on those contributions is $120,000 (since 1 July this year). And you can even use the bring-forward rule, which is 3 years of future contributions ($360,000) until your 75th birthday.

https://www.ato.gov.au/individuals-and-families/super-for-individuals-and-families/super/growing-and-keeping-track-of-your-super/caps-limits-and-tax-on-super-contributions/non-concessional-contributions-cap

 

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