INSIGHTS

The Australian tax landscape is shifting again - this time in a way that may profoundly affect the financial lives of high-net-worth individuals and SMSFs. The government has announced a proposal to levy a 15% tax on unrealised capital gains for super balances above $3 million. If enacted, this will remove the  “realised gains” tax basis where you have received the cash to pay your taxes - and in doing so, introduce new risks and liquidity challenges - especially for investors with illiquid assets.

Let’s start with a simple truth: taxing unrealised gains means taxing money you haven’t actually got.

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What’s Changing?

Under the current rules, superannuation funds pay tax on income and realised capital gains - those that are actually cashed in. But beginning July 1, 2025, individuals with more than $3 million in total superannuation assets may be taxed annually on the increase in value of their holdings, even if they don’t sell anything.

This change is not just technical. It’s philosophical. It redefines wealth not as cash in hand, but as an estimate on paper. And it forces trustees and members to pay real tax on theoretical profits - profits that may later evaporate in a market downturn.

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The Impact on Super Funds

This is especially troubling for SMSFs and large-balance super funds holding concentrated or illiquid assets - like property, private equity, or private credit.

These are not the kinds of assets you can sell on a Monday to pay a tax bill by Friday.

A fund might hold a $6 million portfolio consisting of illiquid assets that appreciates on paper by $300,000. Under the proposed regime, it could face a $45,000 tax obligation - with no cash inflow to match.Some SMSF investors may consider using a limited recourse borrowing arrangement (LRBA), where the fund borrows against a single asset with recourse limited strictly to that asset. It's a useful tool, but tightly regulated, and not suitable for every fund or asset class.

The question is no longer just “how do I invest wisely?” It’s now “how do I fund a tax bill that arrives regardless of what I sell?”

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The Rampart Solution: Liquidity Without Liquidation

Just to be clear, we didn't start Rampart to solve this problem - we want to give investors with assets the ability to do more with those assets i.e. unlock liquidity from your existing assets - without selling them.

We provide asset-backed loans to high-net-worth individuals who need to meet obligations like this new tax, while keeping their long-term investments intact.

Rather than rushing to liquidate your superannuation holdings at inopportune times, you can manage the potential scenarios this new ruling may bring - and access liquidity by borrowing against assets held outside your super (such as private company shares, investment property, or digital assets, etc). This approach allows you to meet tax obligations while preserving the long-term integrity of your super portfolio.

You never know - you might end up buying undervalued assets from an SMSF that’s selling down their portfolio without this tool in their arsenal.

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Final Thoughts

The $3 million tax on unrealised gains is not merely a policy tweak; it's a structural challenge for many superannuation investors.  It challenges the traditional rhythm of investing by introducing unexpected cash demands. It turns patient, long-term capital into a liquidity puzzle.

Rampart is here to help solve that puzzle - not by forcing compromises, but by offering smart, asset-backed funding solutions. Because your wealth strategy should reflect your vision - not be distorted by timing mismatches between growth and tax.

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Disclaimer: Rampart Capital does not provide financial, tax, or investment advice. The information in this article is general in nature and for informational purposes only. Individuals should seek independent advice from a qualified tax or financial advisor before making any decisions based on their specific circumstances.