Market valuations of unlisted business interests for the Division 296 cost-base reset.
The new Division 296 tax lets SMSF trustees make a one-off, irrevocable election to reset asset cost bases to their market value at 30 June 2026. For funds holding private company shares, unit trust interests or business assets, that reset is only as good as the valuation behind it. Oliver Group prepares independent, signed retrospective valuations at the 30 June 2026 date: fixed fee confirmed before you engage.
Yes: if your SMSF holds unlisted assets and the trustee intends to make the Division 296 cost-base reset election, the fund needs a defensible market valuation of those assets as at 30 June 2026. The election, introduced by the Treasury Laws Amendment (Building a Stronger and Fairer Super System) Act 2026, resets asset cost bases to their 30 June 2026 market value for Division 296 purposes; it applies on a whole-of-fund basis, is irrevocable, and must be lodged by the due date of the fund's 2026–27 annual return. Listed shares have a market price; private company shares, unit trust interests and business assets do not: an independent retrospective valuation establishes the value the reset relies on. Oliver Group prepares these valuations at fixed fees from $1,495 + GST. Oliver Group is an independent valuer, not a registered tax agent: whether to make the election is a decision for the member and their adviser.
What Division 296 is, in one paragraph
Division 296 is the new tax on superannuation earnings attributable to large balances, enacted when the Treasury Laws Amendment (Building a Stronger and Fairer Super System) Act 2026 received Royal Assent on 13 March 2026. From 1 July 2026 it adds 15% tax on the share of realised earnings attributable to the part of a member's total superannuation balance between $3 million and $10 million (30% total), and 25% on the share above $10 million (40% total), with both thresholds indexed. Critically, the final design taxes realised earnings: and that is what makes the 30 June 2026 valuation matter: growth that accrued before 1 July 2026 can be quarantined from the new tax, but only at the value the fund can substantiate at that date.
The cost-base reset election, and why it turns on a valuation
Trustees of self-managed and small APRA funds can elect to reset the cost base of fund assets to their market value as at 30 June 2026, for Division 296 purposes only. The election applies to the whole fund, every asset, not a selection, it is irrevocable, and it must be made by the due date of the fund's 2026–27 annual return. For listed shares, managed funds and cash the 30 June 2026 value is a matter of record. For everything else the fund holds directly, shares in a private company, units in an unlisted trust, an interest in a business, the reset value is whatever the fund can defend with evidence. An undervalued asset at the reset date means pre-existing growth gets taxed as a post-commencement realised gain later; an overvalued one is the kind of position the ATO's valuation guidance exists to unpick. Either way, the number carries real tax consequences years into the future, which is exactly the situation the ATO's market valuation guidance says calls for independent, documented evidence.
What we value: and what we don't
- ·Shares in private companies held by the fund, including minority parcels with discount analysis
- ·Units in unlisted trusts, including fixed and hybrid trusts
- ·Directly held business interests and goodwill
- ·Loans and instruments whose value depends on an underlying private business
- ·We do not value real property: direct real estate holdings need a qualified property valuer, and we can work alongside one so the fund's whole asset schedule is covered
A note on assets held through companies and trusts
The reset applies to the fund's own assets. Where the fund holds shares in a private company or units in a trust, it is those shares or units that get a reset value: the assets inside the company or trust do not receive their own reset. That makes the valuation of the interest itself, with appropriate consideration of control, marketability and the underlying business, the load-bearing number. This is standard territory for a business valuer and unfamiliar territory for a fund administrator working from book values.
This is now a retrospective valuation: the discipline matters
30 June 2026 has passed, so every reset valuation is retrospective: it must rely on what was known or reasonably knowable at that date, not on hindsight. Trading results announced later, offers received later and conditions that emerged later are excluded, and the report documents that discipline explicitly. Retrospective work is a core Oliver Group discipline: the same evidentiary rules we apply to retrospective CGT valuations apply here, and the working file is retained for 10 years so the position can be substantiated if the fund's auditor or the ATO asks.
Timing and fees
The election is due by the due date of the fund's 2026–27 annual return, which sounds distant: but the valuation evidence is strongest while the 30 June 2026 picture is fresh: management accounts for the period exist now, and the people who know the June 2026 trading position are still available now. The exact fixed fee is confirmed in writing before you engage. Oliver Group's fees are set by the annual turnover of the business: a Small Business Valuation is $1,495 + GST for turnover under $2 million, a Medium Business Valuation is $2,495 + GST for turnover between $2 million and $10 million, and a Large Business Valuation is $3,495 + GST for turnover over $10 million. Small-business reports are delivered in 2 business days and medium-business reports in 3 business days; the delivery date for a Large Business Valuation is agreed before commencement. Delivery time starts once payment and all required information have been received. Retrospective valuation dates are +$495 each and additional entities are +$795 each. The fee is fixed in writing before work begins and never depends on the concluded value.
Who does what
Oliver Group prepares the independent market valuation and nothing else. Whether the fund should make the election at all, modelling the member's balance against the $3 million threshold, weighing the irrevocability, lodging it with the 2026–27 return, is advice, and it belongs to the fund's accountant, administrator or financial adviser. We are not a registered tax agent and do not provide tax or financial advice. Most engagements arrive instructed by the fund's accountant; we deliver a report they can put straight into the fund's file alongside the auditor's evidence requirements.
Common questions.
Does my SMSF need a valuation for the Division 296 cost-base reset?+
If the fund holds unlisted assets, private company shares, unit trust interests, a business, and the trustee intends to elect, then practically yes. The reset sets each asset's cost base to its market value at 30 June 2026, and for unlisted assets that value has to be substantiated with evidence, not book value. Listed holdings and cash need no valuation report.
When is the Division 296 reset election due?+
By the due date of the fund's 2026–27 annual return. It is made once, applies to the whole fund, and is irrevocable. The valuation itself is best prepared well before then: the evidence at the 30 June 2026 date is strongest while contemporaneous records and people are still available.
Is this the same as the annual SMSF valuation my auditor already asks for?+
No, though they are related. Trustees must already value fund assets at market value each 30 June for the accounts, and auditors ask for evidence supporting it. The reset election raises the stakes on the 30 June 2026 number specifically, because it permanently sets the cost base Division 296 works from. A book-value estimate that passed audit in a normal year is a much weaker foundation for an irrevocable election with long-term tax consequences.
What if the fund holds its business through a company or trust?+
The fund's asset is the shares or units, and that is what gets valued and reset: the assets inside the entity do not get their own reset. The valuation therefore has to deal properly with the interest itself: the underlying business value, then the control, marketability and rights attaching to the specific parcel the fund holds.
What does a Division 296 reset valuation cost?+
The fee is set by the annual turnover of the business being valued: $1,495 + GST under $2 million, $2,495 + GST from $2 million to $10 million, and $3,495 + GST over $10 million. Retrospective dates are +$495 each and additional entities +$795 each. The fee is confirmed in writing before any work begins and never depends on the concluded value.
Can you advise whether my fund should make the election?+
No. That is tax and financial advice, and it belongs with the fund's accountant or adviser: the decision depends on the member's balance trajectory, the fund's asset mix and the irrevocability of the election. Oliver Group's role is the independent market valuation the decision and the election rely on.
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