CGT Reform for SMSF and Super Funds: How the 1 July 2027 Changes Apply Inside Super

General information only. This is not tax or financial advice. Consult a registered tax agent or licensed financial adviser for advice specific to your situation.

Budget 2026 replaced the 50% CGT discount for individuals with cost base indexation plus a 30% minimum tax on real capital gains from 1 July 2027. The headlines focused on property investors and share traders — but Australia’s $4 trillion superannuation pool has always operated under a different tax framework to individuals. Super funds — both self-managed (SMSF) and APRA-regulated retail/industry funds — pay 15% on income in accumulation phase, an effective 10% on CGT-discounted gains, and 0% in pension phase up to the Transfer Balance Cap. None of those rate settings were directly changed in Budget 2026.

So what changes inside super, and what doesn’t? The answer matters for the roughly 600,000 SMSFs holding around $1 trillion of assets and for the ~15 million members of APRA funds whose retirement balances grow under the same CGT framework. The short version: super’s 1/3 CGT discount (which produces the famous 10% effective rate on long-held assets) and the pension-phase exemption appear to be retained per Treasury’s fact sheet — but a quiet interaction with the new 30% minimum tax is still being scoped, and the timing of pension-phase transitions across 1 July 2027 deserves planning attention.

The short version: SMSF trustees and APRA-fund members — the 1/3 SMSF CGT discount and the pension-phase exemption appear to be retained per Treasury’s fact sheet. That means the famous 10% effective CGT rate on long-held assets in accumulation phase, and 0% in pension phase, both survive the reform on day one. BUT there is a structural question Treasury hasn’t yet answered: does the new 30% minimum tax on real capital gains apply to super funds whose statutory rate is 15%? If it does (unlikely on Treasury’s signalling but legislatively possible), super accumulation-phase CGT could ratchet up materially. Watch the Exposure Draft.

Translation: for now, plan as if super CGT stays at ~10% on discounted gains and 0% in pension phase. But don’t crystallise gains pre-reform purely on speculation that the rules will get worse — the signalling is that they won’t.

For the cross-asset overview (individuals, trusts, partnerships) and Treasury’s source examples, see the master article: 50% CGT Discount Reform: Cost Base Indexation + 30% Minimum Tax from 1 July 2027.

How super funds got taxed before 1 July 2027

Before walking through what changes, here’s a quick refresher on how super tax works — because the rate structure is what makes the reform’s impact on super so different from its impact on individuals.

Super has three internal tax phases, and they apply per member, per account, not per fund:

Phase	Income tax rate	CGT on assets > 12 months	Notes
Accumulation phase	15%	10% (15% × 2/3 after 1/3 discount)	The default phase for working-age members building a balance.
Pension phase (retirement income stream)	0%	0%	Available from preservation age (60 for most) once you’ve met a condition of release. Capped at the Transfer Balance Cap.
Transition to retirement (TTR)	15% (since 2017)	10%	Pre-retirement income stream — once treated like full pension phase, now taxed like accumulation.

The CGT discount inside super has always been 1/3, not 1/2 — that’s a deliberate Parliament setting because super already gets concessional 15% rates on income generally. The math: a $90,000 capital gain on shares held > 12 months in an SMSF accumulation account becomes $90,000 × (1 − 1/3) = $60,000 taxable, taxed at 15% = $9,000 tax. Effective rate on the nominal gain: 10%.

In pension phase the same disposal produces $0 tax. The asset is supporting a retirement income stream and the fund earnings supporting that stream are tax-exempt.

These are the rate settings the Budget 2026 announcements do not directly touch. The reform changed CGT for individuals — replacing the 50% discount with cost base indexation plus a 30% minimum tax — but the super fund tax framework was not part of that package. Treasury’s fact sheet on the CGT reform explicitly references “individuals, trusts and partnerships”; super funds operate under separate sections of the ITAA 1997 (mainly Division 295 and Subdivision 295-F for CGT events).

The Transfer Balance Cap remains the binding constraint on pension-phase tax exemption — $2.0m as of 1 July 2025 with indexation. Earnings on amounts above the TBC stay in accumulation phase at 15% / 10% CGT, with the additional Division 296 layer on member balances above $3m from 1 July 2026.

Timeline — what matters for super trustees and members

The dates below pin down which Budget 2026 trigger points matter inside super, and when Division 296 (the separate $3m super tax) interacts with the new CGT regime.

Date	What happens	What it means for super
12 May 2026	Budget 2026 CGT reform announced.	No immediate impact on super fund tax. The 15% accumulation rate, 10% effective CGT, and 0% pension-phase exemption are all unchanged on announcement.
From 12 May 2026	Anti-avoidance integrity rules apply to CGT events shifted across 1 July 2027.	If a fund trustee artificially crystallises a gain pre-reform purely to dodge a perceived future tax, integrity rules may apply. Normal portfolio rebalancing is unaffected.
2026-27 income year	Last full FY where super accumulation-phase disposals get the established 1/3 CGT discount on the whole gain, under unchanged interaction with the (now-being-replaced) individual 50% discount.	Trustees who were planning to rebalance anyway may prefer this window over post-reform years if there’s any doubt about how the new rules interact with super.
30 June 2027 (Wed)	Last day to crystallise gains under the pre-reform framework — for any taxpayer, including super funds.	Cut-off date for funds that want certainty about treatment. Settlement (not contract date) controls for most CGT events.
1 July 2027	CGT reform start date. Cost base indexation + 30% minimum tax begin for individuals, trusts, partnerships. Open question: does the 30% minimum bind for super at 15%? Treasury signalling is no — super is taxed in its own framework.	Until Exposure Draft legislation is released, super trustees should plan on the assumption super CGT continues at 10% effective on the discounted portion.
From 1 July 2027	Split treatment begins for SMSF-held assets bought before that date.	If the new individual-style indexation applies inside super, day-count apportionment between pre- and post-reform portions kicks in. If it doesn’t, the SMSF 1/3 discount continues to apply across the full hold.
1 July 2028	Treasury’s separate 30% minimum tax on discretionary trust distributions begins (different reform).	If a discretionary trust holds CGT-discounted assets and distributes to an SMSF beneficiary, that interaction needs checking. Most SMSF-owned trusts are unit trusts, not discretionary — discretionary-trust-to-SMSF distributions are uncommon but possible. See the discretionary trusts article for that mechanism.
1 July 2030	Division 296 ($3m+ super balance) tax has had three full FYs of operation. CGT events inside large super balances now interact with both SMSF-level tax AND member-level Division 296 top-up calculations.	High-balance members realising CGT events post-reform face two layers: SMSF tax (above) plus Division 296 individual-level top-up on the portion of earnings attributable to balances above $3m.
31 October 2028	First SMSF annual returns covering reform-period disposals.	Tax agents working on SMSF returns for 2027-28 will be the first to apply the new rules (whatever shape they take) inside super.

The big takeaway: most of these dates are placeholders, because Treasury’s published position is that the CGT reform applies to individuals, trusts and partnerships — not superannuation funds, which sit in their own tax framework. The 1/3 SMSF discount + pension-phase exemption + 15% accumulation rate are expected to continue. But until the Exposure Draft legislation lands (expected late 2026 / early 2027), trustees should monitor.

How time changes your tax bill inside super

Even on the assumption super’s rate framework is preserved, the interaction of the reform with super has three time-sensitive moving parts that don’t show up for individual investors:

1. Holding-period split inside super — the accumulation/pension phase distinction. If a fund switches to pension phase across the reform date, the CGT events triggered by the segregation method (or proportional method) of asset allocation can crystallise gains right when the new rules take effect.
2. Indexation effect on slow-growth defensive assets in accumulation — Australian bond ETFs, term deposits, infrastructure trusts often produce nominal returns close to CPI. If indexation does apply inside super, real gains shrink toward zero, offsetting the loss of the 1/3 discount.
3. The 30% minimum tax vs super’s 15% statutory rate — this is the structural question. Super’s headline rate is 15%, well below the new 30% minimum. If the minimum binds for super (it shouldn’t on Treasury’s signalling, but legislative drafting will confirm), accumulation-phase CGT could effectively double. If it doesn’t, no change.

Watch this one: if Exposure Draft legislation extends the 30% minimum tax to super accumulation phase, the 10% effective rate on long-held assets becomes a 20% effective rate (30% × 2/3 after 1/3 discount). That’s a doubling. Pension phase remains 0% either way. Trustees of large accumulation balances should price both scenarios into any portfolio rebalance straddling 1 July 2027.

Four sensitivity scenarios on a $200,000 SMSF gain

Take a $200,000 nominal capital gain on a parcel held 10 years inside an SMSF — 5 years pre-reform, 5 years post — at various phase and rule combinations:

Scenario	Phase / rules	SMSF tax	Effective rate on nominal gain
Accumulation, no reform interaction (1/3 discount preserved, 30% min does NOT apply to super)	$200k × 2/3 × 15%	$20,000	10.0%
Accumulation, reform applies inside super (indexation on reform portion, 30% min on super at 15% does NOT bind)	Legacy share ~50%: $100k × 2/3 × 15% = $10k. Reform share $100k less 13.1% indexation = $86.9k real × 2/3 × 15% = $8.69k. Total	~$18,690	9.3%
Accumulation, reform applies AND 30% min binds inside super	Legacy: $10k. Reform: $86.9k × 30% (min) = $26,070. Total	~$36,070	18.0%
Pension phase throughout (TBC respected)	$0	$0	0%

The first row is the baseline (status quo continues). The second row is better than baseline because indexation now shelters part of the reform-portion gain on this 7%/yr nominal-growth asset. The third row is the worst case — a structural ratchet from 10% to 18% effective — and depends on whether the 30% minimum applies to super funds. The fourth row is the most-favoured outcome: pension phase erases CGT entirely, as it always has.

Plain English: trustees can’t fully model their post-reform CGT exposure until the Exposure Draft clarifies whether the 30% minimum applies to super. Most SMSF advisers expect it won’t — super already has its own rate framework, and Treasury fact-sheet wording confines the reform to individuals, trusts and partnerships. But it’s not yet legislated.

The three-bucket transition, applied to SMSF-held assets

Treasury’s three-bucket framework still applies, with super-specific math:

Bucket	Description	Treatment inside super
A	SMSF acquired AND disposed before 1 July 2027	No change. 1/3 discount applies. 10% effective CGT rate on assets held > 12 months in accumulation. 0% in pension phase.
B	SMSF owned before 1 July 2027, disposed after	Split treatment, IF the reform extends inside super. If it doesn’t (Treasury’s likely position), continues as Bucket A. If it does, day-count apportionment between legacy 1/3-discount portion and reform indexed-real-gain portion.
C	SMSF acquired on or after 1 July 2027	Depends on legislative scope. If reform applies inside super: indexation on cost base + 30% min tax (only binding if super’s 15% rate falls below 30% — which it does). If reform doesn’t apply: 1/3 discount continues.

The unknown across all three buckets is the same: scope of the legislation. Pension phase remains 0% under any interpretation — the pension-phase exemption sits in Subdivision 295-F ITAA 1997 and is unaffected by the CGT reform’s individual-focused architecture.

Worked example 1 — Bucket B SMSF accumulation phase sale (BHP shares)

The Patel SMSF, in accumulation phase for both members (Aarav, 52, and Priya, 49), holds 5,000 BHP shares purchased on 1 March 2020 at $44.00/share. Cost base: $220,000 + $50 brokerage = $220,050.

The trustees decide to rebalance and sell all 5,000 BHP on 1 March 2030 at $74.00/share. Sale proceeds: $370,000 − $50 brokerage = $369,950.

Capital gain: $369,950 − $220,050 = $149,900.

Hold period: 1 March 2020 → 1 March 2030 = 10 years (3,653 days). Days pre-1 July 2027: 2,679 days (~73.3% of total hold). Legacy share of the gain: $149,900 × 73.3% = $109,876. Reform share: $149,900 × 26.7% = $40,024.

Now run the math under both Treasury-position interpretations.

Scenario (a) — Treasury’s likely position: reform does not extend to super CGT

The Patel SMSF continues to apply the 1/3 SMSF discount across the whole gain, taxed at 15%.

• Full gain $149,900 × (1 − 1/3) = $99,933 taxable.
• Tax at 15% (SMSF rate): $14,990.
• Effective rate on nominal gain: 10.0%.

This is the status quo — what would have happened under the old rules. No change from the reform.

Scenario (b) — Hypothetical: reform extends to super with same 30% minimum

If the new individual-style rules applied inside the SMSF — with indexation on the reform portion (assume 7.7% CPI uplift over 3 reform-period years) and the 30% minimum tax binding because 15% < 30% — the math becomes:

• Legacy portion ($109,876): apply 1/3 discount as today. $109,876 × 2/3 × 15% = $10,988.
• Reform portion ($40,024): indexation uplift on the asset cost base attributable to the reform-period portion. Approximate by applying the 7.7% uplift factor to the reform-period gain: real gain ≈ $40,024 × (1 − 7.7% × proportional cost base interaction) ≈ $37,000 real. Taxed at the GREATER of SMSF rate (15%) and the 30% minimum: $37,000 × 30% = $11,100.
• Total SMSF tax: $22,088.
• Effective rate on nominal gain: 14.7%.

A 47% increase in SMSF tax versus the status quo, on this specific asset. The increase scales with the reform-portion share, so it will compound for parcels with shorter pre-reform holds.

Plain English: under Treasury’s most likely interpretation (scenario a), nothing changes for the Patel SMSF’s BHP sale. Under the worst-case interpretation (scenario b), tax rises from $14,990 to ~$22,000 — a $7,000 hit. Trustees should monitor the Exposure Draft and plan portfolio actions assuming scenario (a) is the live answer, but pricing scenario (b) as the downside.

Worked example 2 — Pension phase exemption preserved (Nguyen SMSF)

The Nguyen SMSF has two members — Linh (61) and Quan (60). They both meet a condition of release in late 2027 and transition fully to pension phase on 1 July 2028, with both members’ balances within their respective Transfer Balance Caps ($2.0m each as of 1 July 2025, indexed).

The fund holds a portfolio of ASX 200 ETF units, originally bought between 2015 and 2024 with an aggregate cost base of $850,000. By 1 July 2032, that portfolio is worth $1.5m — a $650,000 unrealised gain.

On 1 July 2032, the trustees sell the entire ETF position to rebalance into income-producing assets (term deposits, infrastructure trusts).

Pension-phase tax on the gain: $0.

This is unchanged by the Budget 2026 reform under any interpretation. Subdivision 295-F ITAA 1997 exempts earnings on assets supporting a retirement income stream, including capital gains on disposal. The reform restructures CGT for individuals — it does not touch the pension-phase exemption.

The Transfer Balance Cap interaction. If either member’s balance exceeded their personal TBC at any point in the lead-up to disposal, the excess would have been forced back into accumulation phase, where it would attract 15% income tax and (depending on the reform’s scope) 10% or higher CGT. Because the Nguyens stayed within their caps, the entire portfolio operated in pension phase and the gain is fully exempt.

Plain English: the timing of pension-phase transition relative to the reform date matters. If the Nguyens had transitioned in 2026 (a year early) and run pension phase across the 2027 changeover, they’d still pay $0 on disposal. If they’d delayed transition to 2030, the gain would have crystallised partly in accumulation (taxable under whatever rules then applied) and partly in pension (tax-free). For SMSFs with members near preservation age and meaningful unrealised gains, transitioning to pension phase ahead of 1 July 2027 removes any uncertainty about how the reform applies inside the fund.

Planning callout: for members aged 60+ with a condition of release met (e.g. retirement, ceasing employment after 60), running an account-based pension over 1 July 2027 is the cleanest way to insulate the SMSF from reform uncertainty. The 0% pension-phase tax is unchanged. The TBC ($2.0m as of 1 July 2025) is the upper limit on how much can sit in this tax-free zone per member. For couples both at preservation age, that’s $4.0m combined — enough for many SMSFs to shelter most of the unrealised gain pool.

Worked example 3 — Bucket C: SMSF buys a new asset in the reform era (CSL shares)

The Smith SMSF — in accumulation phase (both members aged 45 and 43) — buys 200 CSL shares on 1 September 2028 (well after the reform start date) at $290.15/share. Cost base: $58,030 + $50 brokerage = $58,080.

The trustees sell on 1 September 2033 at $410.00/share. Sale proceeds: $82,000 − $50 = $81,950.

Capital gain: $81,950 − $58,080 = $23,870.

This is a pure Bucket C asset — acquired and disposed entirely in the reform era. There is no legacy portion.

Scenario (a) — Treasury’s likely position: super CGT continues as today

• Hold > 12 months: 1/3 discount applies. $23,870 × 2/3 = $15,913 taxable.
• Tax at 15%: $2,387.
• Effective rate on nominal gain: 10.0%.

Scenario (b) — Reform applies inside super, with 30% minimum

• Indexation uplift on cost base. Five years post-reform, CPI at 2.5%/yr: 1.131× uplift. Indexed cost base: $58,080 × 1.131 = $65,688.
• Real gain: $81,950 − $65,688 = $16,262.
• Tax at 30% minimum (binds because super’s 15% rate < 30%): $16,262 × 30% = $4,879.
• Effective rate on nominal gain: 20.4%.

Under scenario (a), the Smith SMSF pays $2,387 — the same as it would have pre-reform. Under scenario (b), it pays $4,879 — more than double. Indexation shelters part of the gain, but the 30% minimum more than offsets that relief.

The break-even between the two scenarios depends on the asset’s real return relative to CPI. For a CSL trade at ~7%/yr nominal growth and 2.5% CPI (real ~4.5%/yr), scenario (b) is much worse than scenario (a). For a defensive asset at ~3.5% nominal growth (real ~1%/yr), scenario (b) becomes neutral to slightly better than scenario (a) because indexation shelters most of the gain and the 30% minimum applies to a small real-gain base.

Plain English: for high-growth equity exposure (CSL, CBA, growth ETFs), Bucket C is meaningfully worse under scenario (b). For defensive holdings (bond ETFs, term deposits, infrastructure trusts), Bucket C under scenario (b) is roughly neutral. Until Treasury clarifies, accumulation-phase trustees should assume scenario (a) but stress-test their portfolio against scenario (b).

Worked example 4 — Division 296 interaction (large SMSF balance)

Anand, 58, has an SMSF balance of $3.5 million as of 30 June 2030. His balance has been over the $3m Division 296 threshold for two FYs already. He’s still in accumulation phase (won’t meet preservation age until 60).

In 2030-31 his SMSF realises a $200,000 capital gain on an ASX share parcel held since 2018 (so it crosses 1 July 2027 — Bucket B). The same fund earns $100,000 in dividends and interest. Total taxable earnings before discount: roughly $300,000 (rough — actual SMSF taxable income calculation involves more line items).

CGT events inside Anand’s super now have two post-reform calculations working in parallel:

Layer 1 — SMSF-level CGT

Under scenario (a) (super CGT continues as today): the $200k Bucket B gain is taxed at 10% effective = $20,000 SMSF tax on the gain alone.

Under scenario (b) (reform applies, 30% min binds): split treatment + indexation + 30% min could push that to ~$30,000–$36,000. We’ll use scenario (a) for the rest of this example.

Layer 2 — Division 296 individual top-up

Division 296 applies an extra 15% tax on the share of earnings attributable to balances above $3m. The earnings for Division 296 purposes include unrealised gains plus realised gains plus income — and the share is computed on an opening/closing balance methodology.

If Anand’s fund had $2.5m of unrealised growth + $300k taxable earnings + (this year) a realised $200k gain, his Division 296 “earnings” attributable to the over-$3m portion of his balance might be approximately:

• Total earnings concept (Div 296): ~$500k (mix of realised, unrealised, income).
• Proportion of balance over $3m: ($3.5m − $3m) / $3.5m = ~14.3%.
• Div 296 taxable earnings: $500k × 14.3% = $71,500.
• Div 296 tax (extra 15%): $10,725 — paid by Anand personally (he can elect to have his super fund release the cash to pay it).

Total CGT-related impost on Anand: $20,000 SMSF-level + $10,725 Division 296 = $30,725 on a nominal $200k gain. Effective combined rate: 15.4% on the nominal gain.

Under scenario (b) — if the 30% minimum applies inside super — the SMSF-level tax rises but the Division 296 tax base is computed on the lower post-SMSF-tax earnings figure, so the increase compounds non-linearly. For very large SMSF balances, scenario (b) becomes material.

Plain English: Division 296 is unchanged by the CGT reform — but it sits on top of any SMSF-level CGT outcome. Members with balances over $3m face two tax layers on the same gain. The CGT reform interpretation affects the bigger of the two layers (SMSF tax); Division 296 then takes a slice of the residual earnings attributable to the over-$3m portion.

For more on Division 296 mechanics, see the Division 296 Super Tax Calculator and consider running parallel scenarios with and without scenario (b) assumptions.

APRA fund members vs SMSF trustees

About 14 million Australians are in APRA-regulated retail and industry super funds (AustralianSuper, Aware Super, ART, HostPlus, REST, UniSuper and many more). These funds also pay 15% on income and an effective 10% on CGT-discounted gains — same rate framework as SMSFs. The reform affects their internal calculations the same way as SMSFs.

The practical difference: APRA-fund members don’t see CGT events directly. The fund’s internal investment activities (rebalancing equity positions, harvesting losses, switching managers) generate CGT events at the fund level. Most members see the result indirectly — via slight changes in unit price (“crediting rate”) or member-level statements showing a small “tax provision” reduction in net returns.

What this means for APRA-fund members:

• No personal action needed for the CGT reform itself. Your fund’s investment team handles the parcel-level math.
• Watch the fund’s annual member report and Product Disclosure Statement post-1 July 2027 — funds may flag whether they expect CGT efficiency to change, especially actively-managed equity options that turn over assets frequently.
• Switching investment options inside an APRA fund typically doesn’t trigger member-level CGT because the fund is the legal owner. It triggers fund-level CGT only when the underlying assets are sold to rebalance, and that cost is socialised across all members.
• Pension-phase products (account-based pensions held inside an APRA fund) still pay 0% on CGT and income — same as SMSFs.

The reform’s impact on APRA-fund net returns will be measured in basis points, not percentage points — but it’s still real for large balances. If scenario (b) (30% minimum applying inside super) becomes law, expect APRA-fund retirement-product disclosures to reference it in their tax efficiency commentary from 2028 onwards.

Open questions Treasury hasn’t clarified

These are the issues SMSF advisers are watching as the Exposure Draft is developed:

1. Does the 30% minimum tax apply to super funds at a statutory 15% rate? Treasury’s fact sheet says the reform applies to “individuals, partnerships and trusts” — super funds are taxed under their own framework (Division 295 ITAA 1997). Most advisers read this as super being out of scope, but the Exposure Draft will be definitive.
2. Does cost-base indexation apply to assets held inside super? Same question, related answer. If the reform applies inside super, indexation does too; if not, the 1/3 SMSF discount continues unchanged.
3. Does the new-build 15-year exemption translate to super? SMSFs can own residential property under in-house asset and other rules. If an SMSF buys a new build post-1 July 2027, does the same per-disposal election (50% discount vs indexation + 30% min) available to individual investors apply to super? Treasury hasn’t said.
4. Discretionary-trust distributions to SMSFs. A separate Treasury reform applies a 30% minimum tax to discretionary trust distributions from 1 July 2028. SMSFs receiving such distributions need to know whether the 30% minimum applies at distribution time or at fund level. (See the discretionary trust article for more.)
5. Transitional valuations. If the reform DOES apply inside super, do trustees need a 1 July 2027 valuation for every fund asset (similar to the property/share valuation requirement for individual taxpayers)? The administrative burden on 600,000 SMSFs would be substantial — most accountants believe Treasury will offer a simplified apportionment method to avoid this.

Until the Exposure Draft is released (best estimate: late 2026 to early 2027), trustees should plan portfolio actions on the assumption that the status quo continues inside super — but monitor the legislation and re-run scenarios when it lands.

Planning levers for SMSF trustees

Even without legislative certainty, there are six planning levers worth considering before 30 June 2027.

Lever 1 — Don’t rush to crystallise gains pre-reform

The strongest signal in Treasury’s fact sheet is that the reform targets individual CGT, not super. Crystallising a long-held SMSF gain on 30 June 2027 purely to “lock in” the current treatment risks paying tax early when the gain was unrealised and tax-deferred otherwise. For accumulation-phase SMSFs, the 10% effective rate already applies — there’s no obvious worse outcome to dodge under scenario (a), and trustees can react to scenario (b) once they see the legislation.

Exception: if you would have sold the asset within the next 18 months anyway (e.g. rebalancing into pension phase, switching managers, or trimming a concentrated position), bringing that sale forward into 2026-27 removes downside-scenario uncertainty at modest acceleration cost.

Lever 2 — Plan pension-phase transitions around the reform date

If a member is at or near preservation age (60) with a condition of release in sight, transitioning to pension phase before 1 July 2027 insulates the supporting assets from any reform uncertainty. Earnings supporting pension liabilities remain 0%-taxed regardless of how the reform interacts with super. For members aged 58-60, this is the single highest-leverage planning move.

For members with balances near the Transfer Balance Cap ($2.0m as of 1 July 2025), respect the cap — pushing more than the TBC into pension phase generates an excess transfer balance with its own tax consequences. Most member balances comfortably fit within their personal TBC, so this isn’t usually the binding constraint.

Lever 3 — Consider contribution timing

Concessional and non-concessional contributions are tax-treated at the time of contribution, not at later disposal. They aren’t directly affected by the CGT reform. But trustees might consider:

• Pre-1 July 2027 contributions that buy assets immediately, locking those assets into accumulation phase under known-old-rules pricing.
• Post-1 July 2027 contributions under whatever the new rules turn out to be.

Practical: contribution caps haven’t changed for the CGT reform. Use the Superannuation Calculator to model the long-term effect of different contribution levels. The cap interactions (concessional $30k/yr; non-concessional $120k/yr or $360k bring-forward in 2025-26) are unaffected by Budget 2026 CGT changes.

Lever 4 — Review concentrated positions in accumulation phase

If your SMSF holds a single asset that has appreciated dramatically — a long-held BHP/CBA parcel, an early CSL position, a property bought before 2010 — the unrealised gain is exposed to whichever interpretation of the reform applies. Stress-test the asset under scenario (b) (30% min binds) and decide whether the position is worth holding under that scenario. Concentration risk and tax risk compound here.

Lever 5 — Defensive assets benefit from indexation, growth assets don’t

If scenario (b) becomes law, indexation favours slow-growth defensive assets (term deposits, bond ETFs, infrastructure trusts) and punishes high-growth equity positions. Trustees who hold growth-heavy portfolios in accumulation phase might consider whether a tilt toward defensive assets makes sense — not solely for tax reasons, but as one factor in a broader allocation review near preservation age.

Lever 6 — Run side-by-side calculator scenarios before any major rebalance

Before a >$50k CGT event inside an SMSF in the 2027-28 or later income years, run both scenarios:

• Scenario (a): current SMSF rules continue. Use the Capital Gains Tax Calculator with the SMSF effective rate (10% on discounted gains, 15% on undiscounted).
• Scenario (b): reform applies inside super with 30% minimum. Use the master article’s calculator with the SMSF marginal rate set to 15% and check whether the 30% minimum binds.

Compare the two outcomes. If the gap is small (say <$2,000), proceed. If the gap is material (>$5,000), wait for the Exposure Draft to land before triggering the disposal.

Linked calculators

Hero — model your super balance and projected tax: Superannuation Calculator — projects your SMSF or APRA-fund balance over time with accumulation- and pension-phase tax modelling.

Model individual CGT under the reform (with SMSF rates): Capital Gains Tax Calculator — supports the marginal rate input that you can set to 15% to approximate SMSF accumulation-phase outcomes.

Model the Division 296 tax on balances above $3m: Division 296 Super Tax Calculator — for members with balances at or near $3m, the Division 296 layer compounds with any CGT reform impact.

What is unchanged

These super tax settings are NOT affected by the Budget 2026 CGT reform under any interpretation:

• Pension-phase exemption — earnings on assets supporting a retirement income stream remain 0%-taxed up to the Transfer Balance Cap. Both income and capital gains.
• Transfer Balance Cap ($2.0m as of 1 July 2025, indexed) — unchanged.
• 15% income tax rate on accumulation phase — unchanged.
• Concessional and non-concessional contribution caps — $30k and $120k respectively for 2025-26, unchanged by this reform.
• Division 293 high-income contribution tax ($250k threshold) — unchanged.
• Division 296 large-balance tax ($3m threshold, extra 15%) — unchanged; sits on top of any SMSF-level CGT outcome.
• Preservation age rules — unchanged. Age 60 for everyone born from 1 July 1964 onwards.
• In-house asset rules and prudential restrictions on SMSF investments — unchanged by this reform.

Sources

• Treasury Budget Paper No. 2, p.21 — Tax Reform — Boosting Home Ownership measure (12 May 2026).
• Treasury fact sheet: Negative Gearing and Capital Gains Tax Reform (12 May 2026).
• Income Tax Assessment Act 1997, Division 295 (taxation of superannuation entities), Subdivision 295-F (pension-phase exemption), section 115-100 (1/3 SMSF discount).
• Income Tax Assessment Act 1997, Part 3-1 (capital gains and losses) — the framework the reform amends for individual taxpayers.

Related reading

• 50% CGT Discount Reform: Cost Base Indexation + 30% Minimum Tax from 1 July 2027 — master article covering the reform across all asset classes for individuals.
• CGT Reform for Property Investors — investment property, new-build 15-year exemption.
• CGT Reform for ASX Share Investors — parcel matching, DRPs, ESS shares.
• CGT Reform for ETFs and Managed Funds — AMIT cost-base adjustments, distributed gains.
• CGT Reform for Crypto — Bitcoin/ETH parcel matching, staking rewards.
• Small Business CGT Concessions After 2027 — retained 15-year exemption, retirement exemption, active asset reduction.
• Budget 2026 Explained: Winners and Losers — full Budget breakdown.