02 Nov 2018 Regarding Senior Tax Counsel’s Report ‘New SMSF reporting deadline looms’
The due date for lodging the September quarter transfer balance account report (TBAR) was 28 October and there has been no change to this date.
We are currently taking an educative and supportive approach where TBARs are lodged late. So, if you haven’t met the deadline but are working towards lodging as soon as possible, you don’t need to seek a formal extension of time. However, you need to be aware that any late lodgment may adversely affect the member’s transfer balance account and may cause reverse workflow for the trustee. We therefore strongly recommend agents discuss with members the potential consequences of late lodgment.
MEMBER 359 writes:
I read this week’s TaxVine and, in particular, read the following and nearly had a heart attack.
Trustees will have to report transfer balance account events in a TBAR if the SMSF has any member who:
has a total superannuation balance greater than $1 million;
had a transfer balance account event occur between 1 July 2017 and 30 September 2018.
On looking further, it seems that the above is missing the important “and” between the two points.
Two conditions needed to be met before a TBAR is required not just having a member with a total super balance (TSB) of more than $1 million. See the ATO website which states:
You must report transfer balance account events to us, on the transfer balance account report (TBAR), by 28 October 2018 if:
- your self-managed super fund (SMSF) has any member with a total super balance (TSB) greater than $1 million; and
- any member had a transfer balance account event occur between 1 July 2017 and 30 September 2018.
For the client concerned, albeit that a member has a TSB over $1 million, there were no events between the set dates.
The first TBAR was required to be filed by 1 July 2018, reporting an income that was received before 30 June 2017 and was continued to be paid after 1 July 2017. The next reporting is if there is a transfer balance account event. See the ATO website which states:
If an SMSF member had a pre-existing income stream, it needed to have been reported to us on the TBAR on or before 1 July 2018. From 1 July 2018, all SMSFs must report events that affect their members' transfer balances. Timeframes for reporting are determined by the total superannuation balances of an SMSF's members.
If I am wrong please let me know.
Senior Tax Counsel Bob Deutsch responds: Thank you Member 359. The two bullet points should be connected by the word “and”. Apologies.