• Service: Tax, Superannuation & Pension Funds
  • Industry: Financial Services, Superannuation
  • Type: Business and industry issue, Regulatory update
  • Date: 17/04/2013

Tax Insights

KPMG's analysis of tax issues and developments.

Paul Abela

Paul Abela
Partner, Tax

+61 2 9455 9576

Could domestic super funds find themselves in pole position? 

by Paul Abela, Financial Services Specialist

Business globalisation, tax harmonisation, superannuation tax, infrastructure spending have all featured heavily recently in the media.

The taxation of trade and commerce continues to be based on rules established over 100 years ago. On the other hand, the taxation of investments is constantly changing (e.g. more countries are not seeking to tax the (local) passive investments of non-resident investors (unless they involve interests in local real estate)).


Is this because trade and investment flows are driven by different commercial considerations and do not share the same 'tax elasticity'?


With one major exception, the ongoing evolution of Australia’s tax laws is generally consistent with these themes. Despite the GFC, there is no clear universal trend to tax retirement income accumulation vehicles (i.e. super funds). An ever aging population with 'insufficient' retirement nest eggs might explain this stance. Australia, however, has been taxing super funds for many years – apparently, to allow them access to the dividend imputation system.


The Obama Administration has recently announced a proposal to exempt from US tax (FIRPTA) any gains recognised by foreign pension funds from US real property interests (to stimulate infrastructure investment). Such a change could put Australian super funds in 'pole' position – being better able to utilise franking credits and tax losses – when bidding for infrastructure investments, simply because they are subject to tax.


Share this

Share this


Our Tax Team assists with corporate tax, transfer pricing, indirect tax, international executive services, R&D incentives, superannuation and more.


KPMG's Superannuation practice offers a range of services to superannuation funds, life offices, employers and fund trustees.