Valuing unlisted SMSF assets for Division 296.

Division 296 commences 1 July 2026 and taxes realised earnings attributable to the part of a member's total superannuation balance above $3 million. Trustees of self-managed and small APRA funds may elect to reset asset cost bases to market value as at 30 June 2026 for Division 296 purposes — a whole-of-fund, irrevocable election due by the due date of the fund's 2026-27 annual return. For unlisted assets such as private company shares and unlisted trust units, that reset value must be evidenced, not asserted: an independent valuation of the underlying business, adjusted for the size, marketability and rights of the specific parcel the fund holds, relying only on information known or reasonably knowable at 30 June 2026.

What does Division 296 actually change from 1 July 2026?

Division 296 adds a second layer of tax on the superannuation earnings of members with very large balances. Enacted when the Treasury Laws Amendment (Building a Stronger and Fairer Super System) Act 2026 received Royal Assent on 13 March 2026, it commences on 1 July 2026 and taxes realised earnings attributable to the part of a member's total superannuation balance above $3 million — an extra 15% on the share attributable to the band between $3 million and $10 million (30% in total) and an extra 25% on the share above $10 million (40% in total), with both thresholds indexed. The first relevant assessment period ends 30 June 2027. The mechanics of the calculation sit with the fund's accountant. What lands on a valuer's desk is one consequential input: the market value of the fund's unlisted assets as at 30 June 2026.

Why are unlisted assets the hard part?

Because listed assets come with a price and unlisted assets only come with evidence. A parcel of listed shares or units in a widely held managed fund has an observable closing price or published unit price at 30 June 2026 — the fund accountant records it and the auditor can verify it in minutes. A parcel of private company shares or units in an unlisted trust has no screen to read the answer from. Its value has to be constructed: what is the underlying business worth, what does the fund's specific parcel actually entitle it to, and what would a willing but not anxious buyer pay for that parcel? Every step of that construction is a judgement, and every judgement needs support. That is why Division 296 is, for most SMSF trustees with unlisted holdings, less a tax question than an evidence question — and the evidence has to be assembled properly.

What is the cost-base reset election, and why does 30 June 2026 matter so much?

Trustees of self-managed and small APRA funds may elect to reset the cost bases of the fund's assets to their market value as at 30 June 2026 for Division 296 purposes. Three features of the election do all the work. It is whole-of-fund — it covers the fund's assets, not a hand-picked few. It is irrevocable — there is no unwinding it later. And it is due by the due date of the fund's 2026-27 annual return, which gives trustees a defined window to get the underlying valuations right. Because the election is whole-of-fund and irrevocable, the 30 June 2026 value is not just another year-end audit figure — it is the permanent starting line from which every future Division 296 calculation for the fund runs. A number that would have passed unremarked in an ordinary audit year now carries consequences that last as long as the fund holds the asset.

What does a defensible 30 June 2026 valuation of private shares or units look like?

It is built in two stages, and both leave a paper trail. First, the underlying business: an independent assessment of what the company or trust is worth as a whole at 30 June 2026, using a recognised methodology, with the reasoning documented and prepared with the ATO's market valuation guidance in mind. Second — and this is the stage annual accounts most often skip — the specific parcel the fund holds. A minority holding is not simply a pro-rata slice of the whole: the parcel's size, its marketability, and the rights attaching to it under the company's constitution, a shareholders agreement or the trust deed all bear on what a buyer would actually pay for it. A signed valuation works through both stages and shows its evidence, so the conclusion can be replicated and tested by someone who was not in the room.

What evidence does each asset type rest on — and who provides it?

Different assets in the same fund rest on different evidence, and no single professional covers all of them. As a working map:

What is the interposed-entity trap?

The reset applies to the fund's own assets — and where the fund holds its business interests through a company or trust, the fund's asset is the shares or the units, not what sits inside the entity. It is the parcel of shares or units that receives the reset value at 30 June 2026; the assets inside the interposed entity get no reset of their own. That distinction changes what has to be valued. Valuing the company's underlying business and stopping there answers the wrong question, because the fund does not own the business — it owns a parcel with particular rights, a particular share of control, and a particular degree of marketability. Trustees who file away a business valuation with no parcel-level analysis have evidenced an asset the fund does not hold. The right scope runs the other way: business value first, then the deliberate step down to the value of the fund's actual holding.

Why does retrospective-evidence discipline matter now that 30 June 2026 has passed?

Because the valuation date is behind us, every 30 June 2026 valuation is now a retrospective valuation — and the discipline that governs retrospective work is strict: only information that was known, or reasonably knowable, at the valuation date may be relied on. A contract signed in August 2026, a customer lost in September, a strong first quarter — none of it existed at 30 June, so none of it belongs in the value. What does belong is the contemporaneous record: management accounts to June 2026, budgets and forecasts prepared before the date, prior transactions in the shares or units, dividend and distribution history, and any genuine offers received. This cuts both ways. Hindsight cannot be used to inflate a value, and it cannot be used to shade one down. A valuation that quietly imports post-June knowledge is exactly the kind that fails when someone checks the dates on its sources.

Is the value already in the fund's accounts enough?

Sometimes — but the two numbers are doing different jobs, and it pays to be honest about the difference. Trustees must already value fund assets at market value every 30 June for the fund's accounts, with evidence the auditor can accept, so a 30 June 2026 figure will exist for every asset regardless. In an ordinary year that figure matters for twelve months and is superseded by the next one. The reset changes the stakes, not the rule: the elected value permanently sets the fund's Division 296 starting point, so an error does not wash out at the next balance date — it compounds for as long as the fund holds the asset. For straightforward assets the accounts figure may serve. For a material parcel of private shares or unlisted units, an independent signed valuation is the stronger foundation for a number the fund will live with long-term.

Should your fund make the election?

That is not our question to answer, and this guide deliberately does not answer it. Whether the election helps or hurts a particular member depends on their balance, their fund's asset mix, and their broader tax position — and that analysis belongs with the member's accountant or licensed financial adviser. Oliver Group is an independent valuer only: we are not a registered tax agent, we do not give tax, legal or financial advice, and the tax position always stays with the client's own adviser. What we contribute is the input the decision turns on — a market value of the fund's unlisted holdings at 30 June 2026 that is independent, evidenced and signed, so that whichever way the trustees and their adviser decide, the number underneath the decision holds.

What does an independent valuation for the reset cost?

Fixed fees, quoted before we start. An Essential valuation is from $1,495 + GST — a signed report on a single methodology, in 10-14 business days. Comprehensive, from $3,995 + GST (15-25 business days), adds a cross-check methodology and suits more complex entities. A Defensible Valuation File, from $8,995 + GST (25-35 business days), is built for holdings where the value is material and scrutiny is likely. Because 30 June 2026 is now a historical date, the retrospective add-on of $495 + GST per historical date applies, and each additional entity valued is $750 + GST. If we are engaged through your accountant or lawyer, the fee is 10% off. Not sure what the parcel is worth before committing? An Indicative Snapshot, from $990 + GST in around 5 business days, gives an indicative range — it is not a signed report, and the fee is fully creditable toward an Essential if you proceed.

What should trustees gather now?

The evidence that decides these valuations is the evidence that existed at 30 June 2026, and it is easiest to assemble while it is still close at hand:

• ·Management accounts and financial statements to June 2026 for each private company or unlisted trust
• ·Budgets or forecasts prepared before 30 June 2026 — dated versions, not later reconstructions
• ·The company constitution, any shareholders agreement, and the trust deed — the rights attaching to the fund's parcel live here
• ·Any transactions in the shares or units near the date, and any genuine third-party offers or approaches
• ·Dividend and distribution history for the parcel
• ·The fund's prior-year asset valuations and the workpapers behind them