Ref: ATD:bt
17 April 2023
Director Tax and Transfers Branch Retirement, Advice and Investment Division The Treasury Langton Crescent PARKES ACT 2600 By Email: superannuation@treasury.gov.au Dear Sir/Madam BETTER TARGETED SUPERANNUATION CONCESSIONS 1.
Thank you for the opportunity to provide comments to the Treasury in relation to the consultation paper titled Better targeted superannuation concessions (“Consultation Paper”).
2.
Pitcher Partners specialises in advising taxpayers in what is commonly referred to as the middle market. Accordingly, we service many clients that may be impacted by any changes to superannuation.
3.
For the reasons explained, we do not support the proposed approach to implement the Government’s policy of taxing the superannuation earnings of individuals with over $3 million in superannuation at a 30% rate.
4.
The Treasurer and Assistant Treasurer’s joint media release of 28 February 2023 first publicly announcing the policy stated that: The concessional tax rate applied to future earnings for balances above $3 million will be 30 per cent.
5.
Additionally, the Consultation Paper (at page 4), states that: This reform is intended to bring the headline tax rate to 30 per cent, up from 15 per cent, for earnings corresponding to the proportion of an individual’s superannuation balance that is greater than $3 million.
6.
However, instead of modifying the tax rate paid by complying superannuation entities, the Consultation Paper’s proposed “Method for calculating tax liability” seeks to use the movements in an individual’s Total Superannuation Balance for an income year as a proxy for earnings.