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Self-Managed Superannuation Funds and National Rental Affordability Scheme Property Dr Paul Thewlis & Margaret Hardy


About the Authors Paul Thewlis and Margaret Hardy are partners in Onyx Wealth. Margaret, Paul, and Onyx Wealth are Authorised Representatives of Millenium3 Financial Services Pty Ltd which is holder of Australian Financial Services Licence number 244252. Paul Thewlis has a Diploma of Financial Services (Financial Planning) and a Diploma of Financial Services (Finance/ Mortgage Broking Management). He also has a Ph.D. and Bachelor of Science from Monash University. Paul has over 25 years’ experience in consulting, marketing and business services, and has been involved in the Financial Services industry since 2002. He is ASIC Authorised Representative No: 342171. Margaret Hardy has a Diploma of Financial Services (Financial Planning). She has extensive experience in financial services and has worked with private, listed and unlisted public companies across a range of industries. She has experience in public accounting and financial planning. She is ASIC Authorised Representative No: 343551.

Onyx Wealth Pty Ltd Suite 7 307 Wattletree Road Malvern East 3147

Š Copyright Onyx Wealth Pty Ltd 2012

P: 1300 1400 15 F: 1300 887 531 E: enquiries@onyx.net.au W: onyx.net.au


Table of Contents Growing Popularity of Self-Managed Superannuation Funds and Property Investment Benefits of SMSF Borrowing to Buy Property Risks, Warnings and Considerations The Balancing Act NRAS Property in SMSF Benefits of NRAS in SMSF An SMSF and NRAS Example: Income An SMSF and NRAS Example: Leveraged Capital Growth How to Set Up an SMSF for Property Purchase

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Disclaimer The information contained in this document (including taxation) is general in nature and does not consider your individual circumstances or needs. The views expressed are those of the authors and not those of Millennium 3. We strongly recommend that you seek the advice of a qualified tax advisor and obtain professional financial advice before making any decision regarding your superannuation needs.


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Growing Popularity of Self-Managed Superannuation Funds and Property Investment In the five years to 30 June 2011, self-managed superannuation funds (SMSFs) have been the fastest growing sector of the Australian superannuation industry with the number of SMSFs growing by 31%. During this period SMSF assets grew by 89%, outstripping total super assets which grew by 45% (Australian Taxation Office, 2012). In our discussions with clients and as reported in recent research the move to self-managed superannuation appears to be driven at least in part by a perceived lack of performance of institutional superannuation and an associated desire for greater personal control by superannuation members (Russell Investments, 2012).

Property and SMSFs While SMSFs have been able to invest in property, the chart below shows that only a small proportion of SMSF assets were held in property as of June 2010. Only 3.6% of SMSF assets were residential property. Asset Holdings by SMSFs (June 2010)

Source: Australian Taxation Office, 2012


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It is not surprising that the investment in direct property has been low given the size of assets held by SMSFs (as shown in the graph below) versus the cost of direct property. Most members (48.7%) held assets of between $100,000 and $500,000. Therefore, most property has generally been either too expensive for most SMSFs to afford; or at least it would require a very high proportion of the asset allocation. SMSF member asset sizes over 5 years

Source: Australian Taxation Office, 2012

SMSF Property Investment Coming of Age In 2007 the Government changed the superannuation act to enable superannuation funds to borrow to buy property under certain specific circumstances. This provided many more SMSFs with the capacity to access property investment. The arrangements for SMSFs to borrow to acquire property can be more complex than buying a property “outside� super. As a result borrowing by SMSFs to buy property has been slow to develop. However the last 12 months has seen a growing interest in this area. Client interest is high and both bank and non-bank lenders have been very active in promoting lending products (De Britt, 2012; The Advisor, 2012).


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Benefits of SMSF Borrowing to Buy Property 1. Greater investment choice Without borrowing most SMSFs simply aren’t large enough to afford property at all. Others may be large enough but would need to use a high proportion of their funds leaving them in a position where their investments are not sufficiently diversified. By borrowing, more SMSFs can now afford to include property in their assets. This gives the SMSF more choice of assets and aids diversification.

2. Leveraged investment Borrowing to purchase property can allow SMSFs to leverage their assets for greater growth. An example of this is demonstrated later in this report.

3. Negative gearing to reduce tax In many cases property investment will be negatively geared. That is, after allowing for interest on borrowings, holding costs and depreciation the property makes a tax loss. This tax loss can be offset against other taxable income of the SMSF (e.g. member contributions, interest on cash assets) to reduce the tax payable by the SMSF.

4. Capital gains tax reduction Taxing of capital gains incurred by SMSFs is different than the rules for “outside super”. A SMSF would pay 15% on capital gains for property sold within 12 months, and effectively 10% where the property is held for over 12 months (the SMSF only needs to declare 2/3 of the capital gain which is taxed at 15%). But most importantly no capital gains tax would be payable if the property is sold when the SMSF is in pension phase.

5. Direct control and member preference Often, people choose to establish an SMSF because they want more direct control over their superannuation investment strategy and asset choice. Property is an asset which gives the SMSF member more direct control and is therefore a natural fit with SMSFs. Many people have a preference for “bricks and mortar” assets which until recently have been out of reach for most SMSFs.


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6. Member investment skill In some cases the SMSF trustee may already have significant skill in property investing which can be utilised by the SMSF. In some cases people may have invested in property “outside super” but exhausted their capacity to continue to invest and an SMSF will allow them to utilise their property investment skills to invest for their retirement “inside super”.

7. Volatility While each individual investment needs to be assessed on its own merits, median Australian property prices when compared with Australian share market indexes such as the all ordinaries have been less volatile. This may suit some SMSF investment strategies. All Ordinaries vs Australian Bureau of Statistics House Price Index 1987 - 2011

Source: Savill-Inns, 2011


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Risks, Warnings and Considerations 1. Sole purpose test It is important for SMSF members and trustees to remember that the member and the SMSF are different entities. The sole purpose of the SMSF is to invest superannuation contributions for the member’s retirement. The SMSFs assets and associated income and costs can’t be mixed with the member’s personal situation. In particular, funds that members contribute into the SMSF stay there until a condition of release is met, e.g. retirement.

2. Rules The Government has lots of rules about what SMSFs can and can’t do. SMSF trustees can’t afford to get these wrong. Trustees should make sure they get good advice and ensure that decisions they make on behalf of the SMSF play by the rules. In particular when it comes to buying and owning property in a SMSF it is important to know that the SMSF is buying an allowable property type and that it is buying it from an allowable vendor. For example the SMSF cannot buy residential property from members of the fund or people who are related parties of the members (e.g. family members).

3. Structures When the SMSF is borrowing to buy a property the property must be purchased using a Bare Trust and a Custodian Trustee with the SMSF as a beneficial owner of the property. The mechanics of this are discussed later.

4. Leverage and loans While there is an upside to leveraging there is also a downside. Leveraging by borrowing to buy a property can increase potential loss and as well as increase growth. For example, if the SMSF borrows at 80% of the property value leaving it with 20% equity, then a 10% reduction in your property value is going to result in a 50% reduction in the SMSF’s net equity.


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5. Liquidity In our discussions with clients we find a major issue preventing people using their SMSFs to invest in property is that their funds are simply not big enough. The typical approach from potential investors is “I have enough in super for 20% of the purchase price plus costs like stamp duty and I’ll borrow the rest”. One major concern with this approach is that property is an illiquid asset – it takes time to sell it and get cash funds. The SMSF must have enough liquidity to enable it to continue to operate and pay its way. Therefore any SMSF investing in property should ensure that the investment strategy allows for a balance between property and liquid assets.

6. Diversification and risk Extending on the previous point, putting “all your eggs into one basket” by using all the SMSF’s funds on one asset may not be acceptable from a risk perspective. Having a level of diversification will spread risk and reduce the reliance on the performance of a single asset class. However SMSFs and associated loans are allowing greater diversification of superannuation fund investment by providing greater access into direct property as an asset class.

7. Negative cashflow reduces cash assets If the SMSF borrows at a high loan to value ratio (LVR), it may find that the property has not only negative gearing but negative cashflow. This is the typical position for many “outside super” property investments. If this is the case, the SMSF will need to have large enough liquid assets and/or cash inflows to allow for this. Ideally an SMSF won’t get into this situation and we’ll address one way to avoid this when we discuss National Rental Affordability Scheme (NRAS) property.

8. Acquisition and holding costs Purchasing property has related costs such as stamp duty which can be substantial. SMSF assets will need to be used to pay these costs and these need to be factored into the overall investment performance of the SMSF.


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Property also has significant holding costs which including property management fees, rates and maintenance.

9. Costs SMSFs have various set-up and operating costs. These include costs for establishing the legal structures, documenting investment strategies, accounting, and auditing. The graph below provides some guidance as to the level of costs involved.

SMSF operating expense ratio by fund size Source: Australian Taxation Office, 2012

When establishing an SMSF the cost of establishing and operating an SMSF need to be compared to the costs associated with institutional superannuation funds.

10. Dependence on Contributions Lenders for SMSFs borrowing for property will take into account member contributions in their servicing calculations. The Trustees for the SMSF need to take into account the impact on the SMSF of these contributions ceasing either through an expected event (eg retirement of member) or an unexpected event (eg.


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unemployment, sickness or injury of member). The Trustees should consider what arrangements (eg. disability or income protection insurance) need to be put in place to ensure the SMSF’s financial position is secure.

11. Insurance Most members of institutional superannuation funds have other benefits such as life and disability insurance. When rolling existing superannuation out of the institutional fund into an SMSF consideration should be given to how these benefits can be preserved or replaced.


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The Balancing Act There are a number of parameters to consider when setting up an appropriate situation with the SMSF borrowing for property purchase. 1. A higher loan LVR will give higher leverage. 2. The value of non-property assets needs to be enough to allow the SMSF to be liquid. 3. Income (eg. member contributions, rent, dividends and interest earned) into the SMSF needs to be enough to ensure it meets the lender’s serviceability requirements. 4. Enough negative gearing to reduce or eliminate tax owed by the SMSF may be advantageous. 5. However there should be not so much negative gearing that the SMSF is unable to access tax benefits by having on-going tax losses in the SMSF. 6. Positive cashflow property that is adding to the SMSF’s assets rather than using them up in property holding costs is also advantageous. 7. Property sale should be timed to obtain the desired capital gains tax position.

How do you make this balancing act work? To get this balancing act to work it’s a case of looking at each individual situation including: 1. Level of member contribution 2. Asset position of the SMSF 3. Property purchase price 4. Property holding costs 5. Rental income 6. Loan amount and interest payments 7. Tax treatment of items such as depreciation


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NRAS Property in SMSF SMSFs can purchase NRAS Approved Property. An annual tax free incentive is provided to owners of NRAS Approved Property each year for ten years by the Government. The NRAS Incentive is $9,981 this year and is indexed against the rental CPI each year. This is an estimated $119,833 tax free per annum over the next ten years. In exchange for the NRAS Incentive the property must be rented out to eligible tenants at a rent at least 20% below market rent as assessed by an independent valuer. Tenant eligibility is based on an income threshold published by the Government. Threshold limits are set relatively high so that most average private tenants would be eligible to rent an NRAS property. The Government estimates that 1.5 million households are eligible. Properties must be approved under the Government National Rental Affordability Scheme. NRAS Approved Properties must be new properties not previously lived in. The properties are privately developed and sold. Property management and NRAS compliance is managed through various Approved Participants which have been allocated NRAS Incentives by the Government. The property owner and NRAS Approved Participant enter into an agreement for the property owner to supply the property and the Approved Participant to manage compliance and supply the NRAS Incentive to the property owner. NRAS Approved Properties are located throughout Australia and can be houses, townhouses and apartments. They can be purchased completed, off-the-plan or as a house and construction package. Due to superannuation act rules SMSFs can only purchase completed or off-the-plan property. The majority of NRAS properties purchased by our clients are priced between $250,000 and $400,000 although there are more expensive properties available.


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Benefits of NRAS in SMSF The benefits for a SMSF to buy an NRAS Property include:

1. Tax free income The SMSF receives an estimated $119,833 in tax free income over ten years which is available to re-invest.

2. Higher negative gearing without negative cashflow NRAS properties have greater negative gearing than equivalent non-NRAS properties. By giving up 20% of the taxable rental income the SMSF increases its tax loss. Normally a loss is undesirable but in this case it is usually offset by the value of the NRAS Incentive. Take for example an NRAS property which has a market rental value of $300 per week. A 20% discount on that rent means the SMSF is giving up $60 per week of taxable income. At the same time, the SMSF gains $190 per week of untaxed income in the form of the NRAS Incentive.

3. New property tax benefits As NRAS properties are new they have greater depreciation allowances than older property. This means greater tax savings potential. A new property will have full depreciation available based on today’s construction costs whereas an older property will only have part or no depreciation allowable (depending upon its age) and the depreciation will be based on the costs of construction of the property at the time it was built which is likely to be much lower.

4. Buying off-the-plan SMSFs buying property off-the-plan can benefit from substantial stamp duty savings. For example, in Victoria and Western Australia, purchasers who buy apartments off the plan prior to construction only pay stamp duty on the land value apportioned to each individual apartment.


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An SMSF and NRAS Example: Income To illustrate how NRAS can benefit an SMSF let’s take an example of a newly established SMSF with $200,000 in cash that has been rolled over from an institutional super fund. The combined income of the two members of the fund is $120,000 per annum and only their 9% employer superannuation is being contributed into the SMSF. We are going to assume that the assets of the SMSF which are not used for buying property are invested so that they are earning 5% per annum. We’ll call these assets “cash” in our examples as if they are held as cash on term deposit. We are just looking at income such as interest and dividends and not taking into account capital growth at this stage. In our benchmark option we’ll invest the $200,000 all in cash assets earning the 5%. So in year one the SMSF is earning $10,000 and the employer contributions are an additional $10,800. That’s a total of $20,800 on which 15% tax is paid ($3,120) giving a net after tax increase in the SMSF assets of $17,680.


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Table 1: First year income of a newly established SMSF with no property investment NO PROPERTY OPENING ASSETS Property Cash TOTAL

0 200,000 200,000

Employer Super Investment Income Rental Income GROSS INCOME

10,800 10,000 0 20,800

Deductible Interest Rental Expenses Depreciation TAXABLE INCOME

0 0 0 20,800

Tax (15%) Add Back Depreciation NRAS AFTER TAX INCOME

-3,120 0 0 17,680

CLOSING ASSETS Property Cash Loan TOTAL

0 217,680 217,680


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Alternatively the SMSF could invest in a property which is not an NRAS property. We’ll assume for the sake of comparison that the property is a new property purchased off the plan. The purchase price is $300,000 plus there are additional costs of $10,000 (eg. stamp duty and legal costs) and the SMSF borrows at 80% LVR. Once the purchase is settled the SMSF is left with a $300,000 property, $130,000 in “cash” and a $240,000 loan. That’s a net asset position of $190,000 with $10,000 spent on acquisition costs. The income of the SMSF in this option includes the same employer contribution. Income from the cash is reduced because some of it has been spent on the property but the SMSF is now earning rental income. Gross income of the SMSF has therefore increased from $20,800 to $32,300. However this is not the full story as we need to look at expenses and tax. The property and loan incur costs including interest, agent fees, rates and maintenance. The SMSF may also include depreciation costs as an expense item cost.


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Table 2: First year income of a newly established SMSF with no property investment and with a normal propery investment NO PROPERTY

NON-NRAS PROPERTY

OPENING ASSETS Property Cash TOTAL

0 200,000 200,000

300,000 130,000 430,000

Employer Super Investment Income Rental Income GROSS INCOME

10,800 10,000 0 20,800

10,800 6,500 15,000 32,300

Deductible Interest Rental Expenses Depreciation TAXABLE INCOME

0 0 0 20,800

-17,040 -3,000 -5,000 7,260

Tax (15%) Add Back Depreciation NRAS AFTER TAX INCOME

-3,120 0 0 17,680

-1,089 5,000 0 11,171

0 217,680

300,000 141,171 -240,000 201,171

CLOSING ASSETS Property Cash Loan TOTAL

217,680


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In summary the SMSF earns more gross income, has more expenses, pays less tax and earns less after tax compared to our benchmark option. The after tax income from buying the property is $11,171, compared to our benchmark which was $17,680. Therefore after our first year the SMSF has a closing balance on its assets which is over $16,000 less than the benchmark option. Finally we have the NRAS option where the property the SMSF purchases is exactly the same as the previous property but is approved for participation in NRAS. The purchase costs are the same but the rent is reduced by 20% and the SMSF receives in return the NRAS Incentive, which is $9,981 for the financial year 2012-13. Again in summary the SMSF earns a lower gross income than the previous property option, has similar expenses, and pays the least tax of all three options. The after tax income is about $1,000 higher than the benchmark option at $18,602. Therefore after our first year the SMSF has a closing balance on its assets which is about $9,000 less than the benchmark option.


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Table 3: First year income of a newly established SMSF with no property investment, a normal property investment and an NRAS property investment NO PROPERTY

NON-NRAS PROPERTY

NRAS PROPERTY

0 200,000 200,000

300,000 130,000 430,000

300,000 130,000

Employer Super Investment Income Rental Income GROSS INCOME

10,800 10,000 0 20,800

10,800 6,500 15,000 32,300

Deductible Interest Rental Expenses Depreciation TAXABLE INCOME

0 0 0 20,800

-17,040 -3,000 -5,000 7,260

-17,040 -3,000 -5,000

Tax (15%) Add Back Depreciation NRAS AFTER TAX INCOME

-3,120 0 0 17,680

-1,089 5,000 0 11,171

-639 5,000 9,981

0 217,680

300,000 141,171 -240,000 201,171

OPENING ASSETS Property Cash TOTAL

430,000 10,800 6,500 12,000

29,300

4,260

18,602

CLOSING ASSETS Property Cash Loan TOTAL

217,680

300,000 148,602 -240,000

208,602


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An SMSF and NRAS Example: Leveraged Capital Growth The biggest part of the SMSF property story is leveraged capital growth. Let’s take the example we’ve been using where the SMSF is investing $70,000 in either in property or some other asset. To illustrate the point about capital growth we’ll not consider the income earned by the various options and simply address the growth in value of the equity the SMSF has in the asset.

Property vs Cash If the SMSF put $70,000 in a cash deposit the SMSF equity would earn income but the original cash asset would not increase in value. So after 10 years the SMSF would have the same $70,000 (plus any interest income earned which we are ignoring). However if the SMSF used the $70,000 plus an 80% loan to purchase a $300,000 and it increased in value by 5% per annum, then the original $70,000 will grow to about $215,000 after 10 years. The growth over the 10 years is shown graphically below. In year two the property asset is behind because some of it has been spent on property acquisition costs but after that the growth in the property puts it well ahead of cash in the bank. The second graph shows a difference between the two options of over $140,000 over the ten years. Value of Property at 5% Growth and Cash Assets Over 10 Years


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Property vs Unleveraged Equity We can also consider the scenario where instead of putting the $70,000 in the bank, the SMSF takes the $70,000 and invests it in unleveraged equities such as shares or managed funds which have potential for asset growth. For ease of comparison let’s assume that both the property and the unleveraged equity grow at 5% per annum. In this example the property equity is again behind in year two but when the SMSF purchases property it is benefiting from growth on a larger asset (5% of $300,000) compared to unleveraged equity (5% of $70,000) The property option in this example sees the SMSF over $100,000 ahead at year ten. Value of Property at 5% Growth and Unleveraged Equity at 5% Growth Over 10 Years


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Now property and other equities don’t grow at the same rate at the same time. So potentially a non-property asset could grow greater than property. So how much would the SMSF’s unleveraged equity need to grow to match the property? In our illustration the answer is 13.3% over ten years, which is represented in the graph below. Experience would suggest that 13.3% would be an extraordinary performance and it’s probable that the SMSF would need to invest in relatively high risk assets to obtain this result. Value of Property at 5% Growth and Unleveraged Equity at 13.3% Growth Over 10 Years


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Risk Assessment Impact of Leveraged Investment – Negative Growth All investment comes with risks. As discussed earlier leveraged investment (property in this example) increases both gains and losses. The graph below illustrates what would happen in the case of the asset reducing in value. If the property purchased by the SMSF reduces in value at 5% per annum over the 10 years the property would be worth $189,000 (about 63% of its original value). As a result the SMSF would have lost its original $70,000 in equity plus an additional $60,000. By comparison a 5% per annum loss in the unleveraged investment would see the original $70,000 reduced to about $44,000 (63% of its original value). That’s a loss of about $36,000. Value of Property at -5% Growth and Unleveraged Equity at -5% Growth Over 10 Years

In considering these risks, the SMSF trustee needs to consider the SMSFs capacity to accommodate a loss situation and the likelihood of negative asset growth over the anticipated investment timeframe for the asset being purchased.


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How to Set Up an SMSF for Property Purchase Self-managed superannuation funds can have up to four members. The SMSF is set up as a Trust with a Trust Deed. The Trust Deed is a document setting the rules under which the Trust is to operate. The SMSF trust is managed by a Trustee or Trustees. The Trustee(s) can either be individuals or a company (known as a Corporate Trustee). If there is a single member of the SMSF the Trustee must be a Corporate Trustee. If there is more than one member then all members must be either Trustees directly (where individuals are Trustees) or Directors of the Corporate Trustee. The superannuation legislation requires that SMSFs cannot borrow against assets held in the superannuation fund. Therefore there are specific structures which enable the property to be held outside the SMSF. To do this a Bare Trust is established with a Corporate Trustee (known as a Custodian Trustee). When buying a property the Custodian Trustee purchases the property which is held in the Bare Trust with the SMSF being the beneficial owner of the property. The name of the Custodian Trustee will be the purchaser on the Contract of Sale. The SMSF borrows using a non-recourse loan with the property as security for the loan. The non-recourse nature of the loan ensures that in the event that the property is sold and the sale price is less than the loan that the lender cannot access other assets of the SMSF to repay the loan. There are restrictions on the type of property an SMSF can purchase which include: •

The property cannot be purchased from a related party (eg. family member).

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The property cannot be land with a contract to build a house.

The property can be a completed property or off-the-plan purchase.


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What has to be done? To purchase the NRAS property in your SMSF the following actions are required. 1. Establish a SMSF which will hold the superannuation assets which will require: a. An SMSF Trust Deed b. A Corporate Trustee c. Australian Business Number (ABN) registration d. Tax File Number (TFN) registration e. Bank account for the SMSF 2. Establish and document an investment strategy for the SMSF 3. Review and structure insurances a. Review existing risk insurances (eg. life insurance and disability insurance) both associated with current superannuation and held directly by the member(s). b. Structure insurances under new SMSF arrangements to meet the member requirements and maintain continuity of benefits. (This may include leaving insurances unchanged). 4. Roll-over funds from the existing superannuation funds to the SMSF 5. Obtain finance approval for the SMSF to borrow for the purchase which will include: a. Assessing borrowing capacity b. Arranging conditional approval for borrowing 6. Establish a Bare Trust which will hold the NRAS property on behalf of the SMSF which will require: a. A Bare Trust Deed b. Corporate Trustee for the Bare Trust (which usually referred to as the Custodian Trustee) c. Australian Business Number (ABN) registration d. Tax File Number (TFN) registration 7. Select property and entered into a Contract of Sale for the property in the name of the Custodian Trustee. 8. Review NRAS contracts 9. Arrange settlement of the property


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Bibliography Australian Taxation Office, 2012. Self-managed superannuation funds: A statistical overview 200910. Canberra: Australian Taxation Office. Available at http://www.ato.gov.au/content/downloads/ SPR00316375n74068.pdf. Accessed on 16 October 2012. De Britt, Rebecca, 2012. Investing in property using an SMSF continues to soar, Smart Property Investment, [online]. Available at http://www.spionline.com.au/home/10952-self-managed-super-funds-make-up-50pc-ofsales. Accessed on 16 October 2012. Russell Investments, 2012. Intimate with Self-Managed Superannuation: The second annual study of SelfManaged Superannuation Funds. Sydney: Russell Investments. Available at http://self-managedsuperfund.com. au/wp-content/uploads/2012/07/SMSF-SPAA-REPORT.pdf. Accessed on 16 October 2012. Savill-Inns, Tim, 2011. Profiting from a property slump, Macrobusiness, [online]. Available at http://www. macrobusiness.com.au/2011/04/profiting-from-a-property-slump/. Accessed on 16 October 2012. The Advisor, 2012. Lender records 50pc spike in SMSFs, The Advisor, [online]. Available at http://www. theadviser.com.au/breaking-news/7740-lender-records-50pc-spike-in-smsfs. Accessed on 16 October 2012.


Onyx Wealth Pty Ltd Suite 7 307 Wattletree Road Malvern East 3147 P: 1300 1400 15 F: 1300 887 531 E: enquiries@onyx.net.au W: onyx.net.au

Š Copyright Onyx Wealth Pty Ltd 2012


Self Managed Super Funds and NRAS Property