Division 296 Started on 1 July, and It Is Not Division 293

Division 296 applies from the 2026-27 financial year to individuals with more than $3 million in super. The numbers are three apart and the two taxes get confused constantly, so start with the distinction: Division 293 is about contributions and hits at $250,000 of income, while Division 296 is about earnings and hits at a $3 million balance.

Key takeaways

  • Applies from the 2026-27 financial year onwards, to total super balances above the large super balance threshold of $3 million for 2026-27.
  • The balance tested for 2026-27 is your balance at 30 June 2027, and from 2027-28 it is the higher of your balances at the start and end of the year.
  • An additional 15% on the proportion of earnings relating to the balance above $3 million, plus a further 10% on the proportion above the very large super balance threshold of $10 million.
  • Not the same as Division 293, which is an extra 15% on concessional contributions once income plus contributions exceeds $250,000.
  • No lodgment from you. The ATO calculates it from what your funds report and issues a notice of assessment.
  • First assessments come later in 2027-28. Nothing lands this year.
  • It does not touch your PAYG withholding or your take-home pay.

Division 293 vs Division 296

These are separate taxes with separate triggers. The similarity is the number and the fact that both add tax to superannuation for higher earners. Everything else differs.

Division 293Division 296
Triggered byIncome plus concessional contributions over $250,000Total super balance over $3 million (the LSBT)
What is taxedYour concessional contributionsA proportion of your super earnings
RateExtra 15%Extra 15% above the LSBT, plus a further 10% above the VLSBT
Threshold$250,000$3 million and $10 million for 2026-27
StatusLong standingNew, first applies 2026-27
First assessmentsExisting annual cycleLater in 2027-28

The practical consequence: a surgeon on $400,000 with $600,000 in super pays Division 293 and not Division 296. A retired business owner with no salary and $5 million in super pays Division 296 and not Division 293. Someone can be caught by both, and they are assessed separately.

If the one you are dealing with is Division 293, the Division 293 calculator works out the liability, and adjusted taxable income explains the income test it uses, which is not your taxable income.

The two thresholds and the layered rates

The ATO uses its own vocabulary here, and it is worth learning because the shorthand in circulation is imprecise.

TermMeans2026-27 value
TSBTotal superannuation balanceYour figure
LSBTLarge super balance threshold$3 million
VLSBTVery large super balance threshold$10 million

The ATO's own construction is that individuals with a TSB above the LSBT are subject to an additional 15% tax on the proportion of earnings relating to their TSB exceeding the LSBT, and individuals with a TSB above the VLSBT are subject to an additional 10% tax on the proportion of earnings relating to their TSB exceeding the VLSBT.

Why "25% above $10 million" is the wrong way to say it

A lot of coverage states a flat additional 25% above $10 million. The total lands in the same place, because the 10% layers on top of the 15% that already applies. But the ATO describes two separate additional taxes with two separate thresholds, and the layering is what makes the structure work. Quoting a bare 25% rate states something the ATO does not say in that form, and it obscures that the 15% keeps applying to the slice between $3 million and $10 million.

The formal name for the measure is Better Targeted Super Concessions. The ATO does not lead with "$3 million super tax", which is the phrasing most commentary uses.

How the ATO says it will work

There is no return to lodge, and nothing to elect until an assessment arrives. In the ATO's words: when your fund reports your account balance to us for the 2026-27 financial year, we will calculate your TSB, and if it exceeds the LSBT or VLSBT we will use your relevant super earnings, reported by your funds, to calculate your Division 296 tax and issue you with a notice of assessment.

One structural change sits underneath that and is easy to miss: the ATO states that the way it calculates total super balances is also changing as a result of the Division 296 legislation. If you have been tracking your TSB against the $3 million threshold using the current method, the figure the ATO arrives at may not be the one you have been watching.

When anything actually happens

WhenWhat
13 March 2026Royal Assent for the Treasury Laws Amendment (Building a Stronger and Fairer Super System) Act 2026 and its Imposition Act, Acts No. 8 and No. 9 of 2026 on the Federal Register of Legislation
1 July 2026Applies from the 2026-27 financial year onwards
During 2027-28Funds calculate and report members' relevant super earnings for 2026-27, with ATO requests starting in November 2027 for defined benefit funds and April 2028 for other APRA-regulated funds. The ATO works out each total super balance, total super earnings and the tax.
Later in 2027-28The ATO begins issuing Division 296 notices of assessment

So the tax is live now in the sense that the 2026-27 year is being measured, and dormant in the sense that nobody receives anything until the following year.

What the detailed ATO pages say

An earlier version of this article listed the calculation method, defined benefit treatment, excluded interests, payment and indexation as unpublished. They were not. The ATO's detailed pages on each were last updated on 29 June 2026, before this article went up, and we had not read them. We have now, and the short version is below.

  • The calculation. The ATO takes the share of your balance above each threshold, as a percentage rounded to 2 decimal places, and multiplies it by your total super earnings. 15% applies to the share above $3 million and a further 10% to the share above $10 million. The Division 296 calculator runs that formula and reproduces the ATO's worked examples.
  • Defined benefit interests. Earnings are measured from the change in the interest's value, and the tax on them is deferred until an end benefit is paid from that interest.
  • Excluded interests. Constitutionally protected funds of state higher level office holders, Judges' Pensions Act interests and foreign super funds, among others, have their earnings counted as nil but still count in your balance.
  • Paying. Payment is due 84 days after the notice of assessment. You can elect within 60 days to release the money from super, and that does not move the due date. The tax is not deductible.
  • Indexation. Both thresholds are indexed to CPI, $3 million in $150,000 increments and $10 million in $500,000 increments. No 2027-28 figure has been published.

Still not published: any ATO figure for how many people are affected or the revenue raised, and the law companion ruling the ATO says it is drafting.

One sourcing trap worth recording

The obvious URL for this topic, ato.gov.au/individuals-and-families/super-for-individuals-and-families/super/division-296-tax, returns a 404. The live hub sits several levels deeper, under growing and keeping track of your super, then caps limits and tax on super contributions. A dead link there does not mean the guidance is gone.

On the contributions side, the general concessional cap for 2026-27 is $32,500, and how salary sacrifice interacts with it is worked through in the salary sacrifice calculator. Employer contributions themselves are covered by the super guarantee calculator at the 2026-27 rate of 12.00%.

Frequently asked questions

What is the difference between Division 293 and Division 296?
Different triggers and different tax bases. Division 293 is triggered by income plus concessional contributions above $250,000, and it taxes your concessional contributions at an extra 15%. Division 296 is triggered by a total super balance above the $3 million large super balance threshold, and it taxes a proportion of your super earnings. You can be caught by one, both, or neither.
What is Division 296 tax?
A tax on the earnings relating to very large superannuation balances, part of the measure the ATO calls Better Targeted Super Concessions. From 1 July 2026, individuals with a total super balance above the large super balance threshold of $3 million for 2026-27 are subject to an additional 15% tax on the proportion of earnings relating to the balance above that threshold.
What happens above $10 million?
A further layer. The ATO sets a very large super balance threshold of $10 million for 2026-27, and balances above it attract an additional 10% tax on the proportion of earnings relating to the balance above that threshold. That sits on top of the 15% that already applies above $3 million, so the total additional tax on that portion is 25%. The ATO describes it as two layers rather than a single 25% rate.
When will I get a Division 296 assessment?
The ATO says it will begin issuing Division 296 assessments later in the 2027-28 financial year. The tax applies to the 2026-27 financial year onwards, but the assessments follow once funds have reported balances for that year.
Do I have to do anything now?
No lodgment is required from you. The ATO says that when your fund reports your account balance for 2026-27, it will calculate your total super balance, and if it exceeds either threshold it will use the relevant super earnings reported by your funds to calculate the tax and issue a notice of assessment.
Is the $3 million threshold indexed?
Yes. The ATO states that both thresholds are indexed in line with the consumer price index: the $3 million large super balance threshold in $150,000 increments and the $10 million very large super balance threshold in $500,000 increments. Indexation starts from 2027-28, and the ATO has not yet published a 2027-28 figure.
Does Division 296 affect my take-home pay?
No. It is a tax on superannuation earnings assessed to you personally after the year ends, not a deduction from your salary. Nothing about PAYG withholding on your wages changes because of it.

Sources

The bulletin and the hub were fetched 2 August 2026. The five detailed ATO pages and both Acts on the Federal Register were fetched 19 September 2026.

The 13 March 2026 Royal Assent date is the assent date the Federal Register of Legislation records for both Acts.

Related

The paygcalculator.au team
Australian PAYG and tax research

We build the calculators and write the guides on PAYG Calculator Australia. Every rate, threshold and due date is checked against current ATO source material and carries the financial year it applies to. Figures in worked examples are computed by the same tax engine that runs the calculators, so the numbers you read match the numbers you get. Corrections to hello@paygcalculator.au.

Published: 6 August 2026 · Updated: 19 September 2026