16 September 2016
Manager
Superannuation Tax Reform
Retirement Income Policy Division
The Treasury
Langton Crescent
PARKES ACT 2600
Submitted via website portal
Dear Sir/Madam
Submission – Superannuation Reform Package
Chartered Accountants Australia and New Zealand welcomes the invitation to make a submission on
the release of exposure draft legislation and regulation on 7 September 2016 for some of the
government’s superannuation and related tax changes.
Please note: our submission responds solely to the issues raised in the exposure draft
legislation and related material and does not imply our views on other aspects of the
superannuation system or on any past or future policy proposals.
Deducting Personal Superannuation Contributions
Chartered Accountants ANZ has long advocated for this change and are pleased that
the government has finally accepted our recommendation.
In these proposed legislative changes the government wishes to restrict a range of
super funds – Commonwealth, State and Territory public sector superannuation
schemes which have defined benefit interests, untaxed super funds and other funds as
provided for in regulations. We do not agree with this restriction for some public sector
superannuation schemes.
Tax Offsets for Spouse Contributions
Chartered Accountants ANZ supports this measure however the government should
allow some flexibility in this provision.
Low Income Super Tax Offset
After much consideration Chartered Accountants ANZ does not support this policy. We
believe the premise on which this measure is structured is not justified by the evidence
and goes against the objective of superannuation.
Objective of Superannnuation
Chartered Accountants ANZ does not agree that the primary purpose of
superannuation is to to provide income in retirement to substitute or supplement the
Age Pension.
Chartered Accountants Australia and New Zealand
33 Erskine Street, Sydney NSW 2000,
GPO Box 9985, Sydney NSW 2001, Australia
T +61 2 9290 1344 F +61 2 9262 4841
charteredaccountantsanz.com
Superannuation Reform Package
Chartered Accountants ANZ submission
We believe the principal objective for Australia’s superannuation system should be “To
create a culture of national saving and self sufficiency in retirement.”
We do not think the objective of superannuation needs to be legislated.
Improved flexibility for Superannuation Contributions for those aged 65 to under
75
We note that on 15 September 2016 the government announced that it would not
proceed with this policy. We are disappointed with this announcement. Regardless we
would like the definition of “gainful employment” to be simplified.
We are a professional body comprised of over 115,000 diverse, talented and financially astute
members who utilise their skills every day to make a difference for businesses the world
over. Members are known for their professional integrity, principled judgment, financial discipline and
a forward-looking approach to business which contributes to the prosperity of our nations.
We focus on the education and lifelong learning of our members, and engage in advocacy and
thought leadership in areas of public interest that impact the economy and domestic and international
capital markets.
We are a member of the International Federation of Accountants, and are connected globally through
the 800,000-strong Global Accounting Alliance and Chartered Accountants Worldwide which brings
together leading Institutes in Australia, England and Wales, Ireland, New Zealand, Scotland and
South Africa to support and promote over 320,000 Chartered Accountants in more than 180 countries.
Should you require any further information or wish to discuss the contents of this submission, please
contact Tony Negline, Head of Superannuation on 02 8078 5404 or by email at
[email protected]
Yours sincerely,
Rob Ward FCA AM
Head of Leadership & Advocacy
Chartered Accountants Australia and New Zealand
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Overview
Chartered Accountants Australia and New Zealand is pleased to comment on the first tranche of draft
legislative and regulatory changes for the government’s superannuation and related tax changes first
announced in the Federal Budget on 3 May 2016.
Objective of Superannuation
Whilst we support defining an objective for superannuation we have concerns about the proposed
objective and five subsidiary objectives.
All other elements contained in the exposure draft
When it announced its recent super and related tax changes the government said that its objective of
many of its proposed changes is to make the super system sustainable, flexible and, if required,
improve the integrity of the superannuation system.
We believe that the government’s proposed changes should be judged on this basis.
In summary our views about the various government policy announcements and whether they meet
the government priorities can be summarised as follows:
Tax deduction for personal super
contributions
Tax offset for spouse contributions
Low Income Super Tax Offset
Improved flexibility for contributions by
older Australians
Chartered Accountants Australia and New Zealand
Sustainable
Flexible
Improve
integrity
Yes
Yes
N/A
Yes
No
Yes
No
N/A
N/A
N/A
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Deducting Personal Superannuation Contributions
Chartered Accountants ANZ is very pleased that the government has decided to proceed with this
policy.
We have advocated for this change for many years to remove an anomaly from the tax system.
Employees and employers have solved this inconsistency by implementing “salary sacrifice”
arrangements so that employees could tax effectively save towards their retirement.
In effect individuals and employers have incurred higher costs because the tax system contained
unnecessary complexity.
It is unacceptable that effectively the same transactions have taken place but have resulted in vastly
different tax outcomes.
By removing this discrepancy, we believe that the overall costs of running the superannuation system
will be cheaper and this will assist, in a small way, to make the system more sustainable.
In addition we believe that this change definitely makes the superannuation system more flexible
because it allows individual taxpayers, if they are also eligible to salary sacrifice with an employer to
chose where they would like the tax benefits to reside. If they choose the salary sacrifice option then
the tax benefits will reside in the super fund but if they personally claim the contribution as a tax
deduction then they will receive the tax benefits personally.
Suggested Amendments to the Exposure Draft
However we believe that there are elements of the proposed law that require adjustment:

Annual paper-trail – at present, a taxpayer is not permitted to claim a tax deduction for personal
super contributions unless they send to their super fund a notice in writing and then the super
fund acknowledges, in writing, that is has received the taxpayer notice (refer to the Section 290170 of the Income Tax Assessment Act 1997 – ITAA97).
The reality however is that many taxpayers find this papertrail confusing especially as there are a
number of circumstances when a super fund cannot accept a notice from a taxpayer (refer to
subsection 290-170(2) of the ITAA97). As a result mistakes are often made in relation to this
paper trail for a wide variety of reasons.
In addition most super funds have found this paper-trail requirement expensive to administer.
When the minority of taxpayers were eligible for this deduction a case could be made for the need
for this paper-trail.
In an ideal world there would be no requirement for it.
If it is deemed be necessary then its need should be reversed. That is it should only have to be
completed if a taxpayer does not intend to claim the contributions as a tax deduction.
In addition many of the rules that restrict the validity of these notices should be revisited with a
view to removing them.
Finally if it is decided that these notices have to be sent between individuals and super funds then
there should be a specific allowance for these to be sent electronically.

Restrictions on deductbilility of personal contributions made to certain defined benefit interests –
Chartered Accountants ANZ does not agree with this limitation. In the exposure draft explanatory
memorandum released on 7 September says that contributions should be exempt from this new
rule because:
These superannuation funds were generally those that linked
accrual of benefits in a defined benefit interest to the period of
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employment of members while permitting or requiring personal
contributions by members.
This statement is true for some older Commonwealth public sector super schemes that have long
been closed to new members (for example, the Defence Force Retirement and Death Benefits
Scheme). However it is not true of other Commonwealth schemes (for example, the Military
Superannuation Benefits Scheme – “MSBS”).
The exposure draft explanatory memorandum goes onto explain that
There would be significant costs if these funds needed to
restructure their rules and benefit calculations to allow their
members to elect that such personal contributions would be
deductible.
We do not accept this statement in relation to schemes structured in a way similar to the MSBS. In
relation the MSBS and other similarly structured super funds the costs of implementing the change
may, in part, relate to the need for anyone wanting to claim their personal contributions as a tax
deduction to exchange documentation with their super fund. Our suggested amendment in point 1
above solves this problem.
Finally, the exposure draft explanatory memorandum says
Members of these Commonwealth public sector
superannuation schemes and members of any similar funds
that choose to receive the same treatment continue to be
able to deduct personal contributions they make to other
types of superannuation funds such as those providing
accumulation benefits, provided the contributions satisfy the
other requirements to be deductible under the income tax
law.
Whilst this statement is true, it does not mention that many public sector scheme rules demand that
employees make post-tax personal superannuation contributions.
If the government persists with this restriction then it should commit to changing its defined benefit
schemes so that members of those arrangements do not compulsorily have to make after-tax
personal contributions to these schemes but could, if they wished, elect to contribute to another super
fund with these types of contributions and claim them as a tax deduction if they so wished.
Tax offset for Spouse Contributions
Chartered Accountants ANZ believes that increasing the cut-off threshold for this measure is long
overdue.
The current threshold is far too low and has not changed since 1 July 1999. Based on average wage
increases over this period its real value has fallen by about 50%.
According to Taxation Statistics issued by the ATO for the first seven years after it was introduced an
average of about 32,500 taxpayers used it. In the 2013/14, only just over 12,000 taxpayers accessed
this concession.
The reduction in the number of taxpayers using this concession appears to have commenced in the
2008 financial year which co-incides with amendments to the rules governing when superannuation
contributions for those under 65 years of age.
However in recent years the decline in the number of taxpayers accessing this concession has
accelerated. The only logical reason for this ongoing reduction is the low income threshold that
currently applies.
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Suggested Amendments to the Exposure Draft
The income threshold for this provision should be indexed each year on 1 July by movements in
average weekly earnings.
In addition an increase in the maximum tax offset available to the contributor should be considered as
this also has not been increased for over 15 years and in real terms has fallen considerably in value.
Low Income Super Tax offset
This measure will provide those with an “adjusted taxable income” – or ATI – of up to $37,000 with a
refund of tax on concessional contributions of up to $500.
ATI is defined to include a taxpayer’s taxable income, total adjusted fringe benefits, target foreign
income, total net investment loss, tax-free pension or benefit, reportable superannuation contributions
less any deductible child maintenance expenditure for that year.
After much thought Chartered Accountants ANZ does not support this measure.
Cost of this measure and how it is funded
In the 2016 Federal Budget the government estimated that it would cost $1.6 billion over the forward
estimates.
On the other hand, the proposed reduction in the concessional cap and the proposed lower threshold
for the higher income earners tax will, according to the governments Federal Budget documents, have
a fiscal “gain” to revenue of $2.5 billion.
It is reasonable to conclude from this result that about 60% of the “gain” to revenue from these two
measures is being used to fund this “contribution tax” refund policy for lower income earners.
Many lower income earners, especially those who have lower salaries throughout many years of their
working life, will be eligible for the aged pension which replaces a very high percentage of a low
income earner’s pre-retirement income (in fact it may pay them more income than they received
throughout their working years).
It is our view that the $1.6 billion cost for the Low Income Super Tax Offset is being funded by mostly
higher income earners, many of whom, with appropriate incentives, could save sufficient money to be
independent of the government in retirement.
In addition according to research released by the Federal Government in 2015, more than one third of
working households pay no net income tax because the taxes their household has paid are returned
via a range of government benefits 1.
Our point here is not to argue about the merits of the various policies that have put these outcomes
into place.
Rather we seek to point out that it has long been recognised that over the next 30 years the Federal
Government has a significant budgetary challenge if all current policies remain in place caused by the
population aging. One solution to this emerging fiscal challenge is to encourage as many taxpayers
as possible to self-fund their retirement income needs and not rely on the age pension.
The reality is that the cohorts that are most likely to achieve this outcome are those earning more than
approximately 120% of average weekly earnings. And it is taxpayers in this cohort who are impacted
the most by the proposed reduction in the concessional cap and the lower threshold for higher income
earners.
1
http://www.theaustralian.com.au/national-affairs/treasury/36m-households-pay-no-net-tax-afterchurn/news-story/4cee19a028067cfc4abe8548829f3dfe
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Many lower income earners miss out on this tax concession
There is significant focus in the exposure draft explanatory memorandum on taxpayers marginal tax
rates:
Currently concessional contributions to superannuation are
taxed at 15 per cent regardless of the individual’s relevant
marginal income tax rate. An individual may have an
effective tax rate that is lower than 15 per cent. The low
income superannuation tax offset will ensure that individuals
who have an effective tax rate below 15 per cent do not pay
more tax on their concessional contributions through their
fund or retirement savings account provider than if they had
received the money as salary or wages and paid tax in their
own hands.
We think this explanation misses an important point regarding tax rates.
You cannot compare, without making a range of adjustments, the flat tax rate scale that applies to
super funds with a progressive tax scale that applies to individuals.
For example based on the current tax scales a super fund with taxable income of $18,201 will have
paid $2,703 in tax. A person with the same taxable income will have paid 19 cents.
So we have the situation that the super fund has paid 15% tax on each dollar of taxable income while
the individual has paid 0.0001% tax on each dollar of the same income amount.
The simplest way of comparing these rates is to determine the average amount of tax paid by
individuals on each dollar of taxable income.
For example a person with taxable income of $90,000 – and a marginal tax rate of 39 per cent
including the Medicare Levy – will pay $22,732 in tax. That is their average tax rate is roughly 25 per
cent. Someone with a taxable income of $200,000 has an average tax rate of 34 per cent but a
marginal rate of 49%. These examples assume the government can legislate an increase to the
income threshold to $87,000 as proposed in Treasury Laws Amendment (Income Tax Relief) Bill
2016.
An individual taxpayer will pay an average of 15 per cent tax – including Medicare Levy – on personal
income when their taxable income is about $43,350.
Taxable Income ($)
*
Marginal Tax Rate*
Average Tax Rate*
20,000
21.0%
1.5%
43,350
34.5%
15.0%
90,000
39.0%
25.2%
200,000
49.0%
34.0%
assuming the 2% Medicare Levy has to be paid
We believe that many lower income earners – in particular those who earn between $37,000 and
$43,350 – miss out on any concession given that the tax they pay on each dollar of personal income
is less than 15%.
If we look solely at the taxable income data of the ATO we estimate that this cohort could be
approximately 1.155 million taxpayers. Based on the same ATO data approximately 2.33 million
taxpayers are eligible for the Low Income Super Tax Offset. That is about a third of taxpayers
paying an average income tax rate of less than 15% on their personal income would receive no
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Low Income Super Tax Offset. (We acknowledge that our analysis here only looks at taxable
income data and does not consider the other potential elements of the Adjusted Taxable Income
definition. As a result our rough estimate of those within the eligible and ineligible cohorts may be
slightly inaccurate.)
Maximum compensation available is inadequate
We also have concerns about the amount of compensation that is available to those who are eligible.
The maximum that is payable each year is $500 for sometime with an ATI of up to $37,000. This is
equivalent to the tax that is payable on $3,333.33 of contributions.
However 9.5% (the current Super Guarantee rate) on Ordinary Time Earnings of $37,000 is $3,515.
In other words indivduals eligible for the Low Income Super Tax Offset are receiving less
compensation than the full refund of the contributions tax they have to pay.
In addition the Low Income Super Tax Offset fails to take into account the tax on super fund earnings
that low income earners will pay while their money is invested in superannuation compared to the
average tax rate they pay in their own name.
Administration process is very expensive
Finally we have a major concern about how this administraton process works and its overall cost.
This process contains a number of steps and movement of money to the super fund, to the Tax Office
and back to the super fund. The costs incurred by super funds to process these transactions should
only be bourne by those who receive the Low Income Super Tax Offset.
Objective of Superannuation
We do not agree with this legislative amendment.
In our view one of the main purposes of legislation is to alter behaviour either in a positive, neutral or
negative way. Legislation does this primarily by imposing penalities for non-compliance with a
particular rule. For example, any superannuation fund trustee that breaches a super law risks being
reprimanded or fined or worse.
However we note the government’s proposal to enact legislation that sets out the objectives does not
include any penalties for non-compliance. We are concerned about the usefulness of the proposal to
legislate. A law without a deterrent for non-compliance is unlikely to change behaviour. If legislation is
enacted there will also be less flexibility to regularly review the objectives every few years to allow for
changing circumstances.
We note the government has imposed no penalty on itself if laws are passed laws or regulations are
put in place that were inconsistent with this objectives for the superannuation system.
Nevertheless we are pleased the government has placed its superannuation objective into a proposed
stand-alone Act of Parliament.
We believe that, in the absence of formal legislation, the superannuation objectives should be made
available in a prominent and public way on relevant government websites. For example, on:

pm.gov.au

treasurer.gov.au

treasury.gov.au

asic.gov.au

apra.gov.au

ato.gov.au
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
moneysmart.gov.au

all major political party websites
It should also be made clear on these websites where any broad political agreement and support from
industry and the community has been obtained for the stated objectives.
Chartered Accountants does not support legislating the objectives of superannuation.
However the objectives should be made widely and publicly available.
Neverthess we are pleased the government has proposed to place these objectives in
a stand alone Act of Parliament.
Report publicy on how policy proposals are consistent with achieving superannuation
objectives over the long term
We are pleased the government has proceeded with this requirement.
However we would also like to see the Government review, and publish findings, every five years on
how well the super system is tracking on meeting the agreed objectives and, if the objectives are to
be legislated, then a progress report should also be a legislative requirement.
Chartered Accountants agrees that all policy changes to the superannuation area
should only proceed if they are consistent with the established objectives and that this
must be demonstrated with each potential change. We also believe there should be
reviews every five years to assess progress to date.
Government’s preferred objective of superannuation
To provide income in retirement to substitute or supplement the Age Pension.
Chartered Accountants ANZ has concerns about the limitations of this objective as we believe it is too
vague. We believe the government needs to detail what it means by “substitute or supplement the
Age Pension”.
One possible interpretation is that the total tax concessions available to each taxpayer for saving for
retirement via the super system and/or the age pension payments they may be entitled to receive
from the Commonwealth is limited to the present value of providing the Aged Pension. We could not
support this interpretation.
Does it mean $1 more or $1 million more than the Age Pension? Or does it mean something
different?
Estate planning integral to the superannuation system
In the exposure draft explanatory memorandum we were concerned to read that the purpose of
superannuation is “not to allow for … estate planning”.
In the past estate planning typically meant the transfer of a deceased’s assets to their heirs and
successors. It is now common for this terms to have a much wider definition and consider not only
planning for death but also other contingencies such as mental or physical ill health.
Given the evolving definition of this term we encourage the government to clearly state what it means
by it.
The “sole purpose test” in the Superannuation Industry (Supervision) Act permits superannuation
funds to exist if benefits are paid on a members retirement, death or disability. As a result, other
legislated rules governing the operation of super funds permits super fund trustees to purchase death
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and disability insurance policies and to pay out members’ interests to either their nominated
beneficiaries or deceased estate.
For many millions of investors these aspects of their superannuation funds is a key issue. And an
important estate planning issue.
Does the government intend to disallow these features in the super system?
We encourage the government to explain what it means by estate planning, what changes it intends
to make to the operation of superannuation funds (if any) and by what date and whether it will allow
any transitional measures.
Our preferred objective for the superannuation system
Chartered Accountants ANZ recommends a more expansionary and visionary principal objective for
Australia’s superannuation system:
To create a national culture of saving and self sufficiency in retirement.
In our view self-sufficiency means full replacement of family income for households earning up to
male average weekly ordinary time earnings – currently just under $83,400 per annum – and then a
reduction from that point. We do not have a firm view on what this reduction should be. One option,
could be the following – a 1% reduction for each additional $10,000 of household income earned. For
example if household income was $133,400 then self-sufficiency would be defined as up to 95% of
that amount.
Take a holistic view of all aspects that may impact on wealth and retirement savings
It is also important to take a holistic view of all aspects that may impact on an individual’s wealth and
retirement savings, such as sources of financial assets other than superannuation, property assets
and debt as well as the costs of funding retirement.
We believe that the principal objective should be expanded to include provision for likely outlays for
old age health and aged care needs. All Intergenerational Reports published to date show that in the
near future these costs will have a significant impact on all Australian governments unless preemptive action is taken.
Consideration should also be given to the implications of other current and proposed government
policies in relevant areas such as tax reform, financial services and social services.
Chartered Accountants ANZ recommends that the principal objective for Australia’s
superannuation system be “To create a national culture of saving and self sufficiency in
retirement.”
We recommend taking a holistic view of all aspects that may impact on wealth and
retirement savings, particularly the funding of health and aged care needs for older
Australians.
We also believe it is important to consider the implications of other current and
proposed government policies in relevant areas such as tax reform, financial services
and social services.
Subsidiary Objetives of Superannuation
We note that the exposure draft explanatory memorandum states five subsidiary objectives for the
superannuation system:

facilitate consumption smoothing over the course of an individual’s life;
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



manage risks in retirement;
be invested in the best interests of superannuation fund members;
alleviate fiscal pressures on Government from the retirement income system
be simple, efficient and provide safeguards.
Where does the government intend to publish these subsidiary objectives?
We would like to see several amendments to these secondary objectives. In our view the secondary
objectives should be as follows:
1. Facilitate consumption over the course of an individual or a family’s lifetime
At present superannuation is treated very much at an individual level. This is the case if we look at
super funds or the tax treatment of contributions or benefits paid from those funds.
However around 59% of Australians aged over 15, based on the 2011 Census, were married or in a
defacto relationship.
Individual taxpayers are required to nominate their spouse on their annual tax returns and eligibility for
the Age Pension is mostly assessed on combined partner income and assets tests.
Eligibility for Family Tax Benefit is assessed on family Adjusted Taxable Income. For most families
the majority of this income will come from the combined effort of parents or guardians.
The objective of superannuation should not cut across how most Australians choose to live.
(As an aside – if the super system permitted spouses to have joint accounts then we would expect,
over time, for the number of accounts in the super system to reduce thereby saving investors fees.)
In addition individuals should be free to choose when they wish to save for retirement and there
should be no penalties for wanting to make additional contributions later in life. Whilst it might be
ideal that individuals will save at a constant rate throughout their working lives, many people find
much of their early working life is used to fund the purchase of a home, raise and educate children
and build an economic base for their family.
2. Be fully funded from savings
3. Be fit for purpose
That is, allow individuals to save for their self-sufficiency in retirement (income, health, aged care and
other needs) which will as a result appreciably alleviate fiscal pressures on government retirement
outlays caused by the age pension as well as old age health and aged care needs and also reduce or
manage the risk of individual outliving their savings.
4. Be simple, co-operative, efficient and cost effective
The superannuation system must be easily understandable to the average consumer and it must also
be co-operative, efficient and cost effective.
The participants in the super industry must use their best endeavours to engage constructively with
individuals.
Much of the heavy lifting to achieve efficiency and cost efficiencies will arise if the regulatory
environment is not overly complex or convoluted. This is not the case at present.
Ideally the tax and regulatory environment should provide incentives for industry participants to
innovate and make use of technological advancements.
We also believe that consistency and brevity is important, especially in the area of regulation.
5. Be competitive, fair and provide appropriate safeguards
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Participants in the super industry must be permitted to compete fairly and ethically in an open market,
and the regulatory environment must not be a barrier to industry competition.
There must also be appropriate safeguards for super fund members so that the potential for fraud and
other crimes is minimised to the greatest extent possible.
Fines for breaching disclosure obligations and other offences must be fit for purpose. In short there
must be no financial advantage for breaching any rules.
6. Be regularly reviewed
All political parties should agree to a regular, bipartisan review of the super system every five years to
confirm that it is meeting its objectives. The primary purpose of the review will be to assess the
strengths, weaknesses, opportunities and threats in the super system.
Chartered Accountants supports the concept of secondary objectives for the
superannuation system and believes the following are a good starting point:
1. Facilitate consumption over the course of an individual or a family’s lifetime
2. Be fully funded from savings
3. Be fit for purpose
4. Be simple, co-operative, efficient and cost effective
5. Be competitive, fair and provide appropriate safeguards
6. Be regularly reviewed
Improved flexibility for Older Australians to make super contributions
Chartered Accountants Australia and New Zealand notes that the government announced on 15
September that it would not proceed with this change.
We are disappointed with this announcement.
We have long had a concern about the definition of “gainful employment’ in the Superannuation
Industry (Supervision) Regulations. This definition has been used to determine eligibility to contribute
to superannuation and to take benefits out of the system. In our experience taxpayers and their
advisers have continually found this definition difficult to understand and apply in practice. This is
compounded by the reluctance of the superannuaton regulators to provide any interpretative
guidance.
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