Will the payments from the Country X, pension schemes be taxed in Australia as superannuation lump sums from a foreign superannuation fund pursuant to section 305-70 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Yes. This ruling applies for the following period : Year ended 30 June 20XX
You became a resident of Australia for taxation purposes. You held interests in Country X pension schemes Fund A and Fund B at Residency Date. After Residency Date, you transferred your total benefits in Fund A to Fund C, Country X pension scheme. You transferred your total benefits in Fund C to Fund D, Country X pension scheme. After Residency Date, you transferred your total benefits in Fund B to Fund E, Country X pension scheme. You transferred your total benefits in Fund E to Fund D. You transferred a portion of your benefits from Fund D to Fund F, Country X pension scheme. You again transferred a portion of your benefits from Fund D to Fund F. During the 20XX income year, you withdrew a Pension Commencement Lump Sum amount from Fund D. The RBA exchange rate on this date was AUD = £pound;0.XXXX. During the 20XX income year, you transferred your total benefits in Fund F to your self managed superannuation fund (SMSF). The exchange rate was AUD = £pound;0.XXXX. This closed Fund F. During the 20XX income year, you withdrew a second lump sum from Fund D. The RBA exchange rate on this date was AUD = £pound;0.XXXX.
During the 20XX income year, you withdrew a third lump sum from Fund D. The RBA exchange rate on this date was AUD = £pound;0.XXXX. During the 20XX income year, you transferred your total remaining benefits in Fund D to a second SMSF. The RBA exchange rate on this date was AUD = £pound;0.XXXX. This closed Fund D.
Income Tax Assessment Act 1997 Section 305-70 Income Tax Assessment Act 1997 Section 305-75 Income Tax Assessment Act 1997 Section 305-80 Income Tax Assessment Act 1997 Section 960-50 Income Tax Assessment (1997 Act) Regulations 2021 Regulation 960-50.01(1) Superannuation Industry (Supervision) Act 1993 subsection 10(1) ATO view documents ATO Interpretative Decision ATO ID 2015/7: Foreign currency translation rules in working out 'applicable fund earnings' under section 305-75 of the ITAA 1997
Applicable fund earnings If an individual taxpayer receives a superannuation lump sum from a foreign superannuation fund more than six months after becoming an Australian resident, section 305-70 of the ITAA 1997 includes in the individual's assessable income any growth (known as 'applicable fund earnings') earned on the foreign superannuation interest while the individual was an Australian resident. The applicable fund earnings amount is worked out in relation to a lump sum paid from a foreign superannuation fund under either subsection 305-75(2) or subsection 305-75(3) of the ITAA 1997. Subsection 305-75(2) of the ITAA 1997 applies where the person was an Australian resident at all times during the period to which the lump sum relates. Subsection 305-75(3) of the ITAA 1997 applies where the person was not an Australian resident at all times during the period to which the lump sum relates.
For subsection 305-75(2) and subsection 305-75(3) of the ITAA 1997, the period to which the lump sum relates is the period during which funds are accumulated in a particular foreign superannuation fund for a member that has a relation to the superannuation lump sum paid by that fund. That is consistent with other parts of those subsections, which also focus on the foreign superannuation fund from which the lump sum is paid. Subsection 305-75(2) of the ITAA 1997 states, if you were an Australian resident at all times during the period to which the lump sum relates, the amount of your applicable fund earnings is the amount (not less than zero) worked out as follows: (a) work out the total of the following amounts: (i) the part of the lump sum that is attributable to contributions made by or in respect of you on or after the day when you became a member of the fund (the start day ); (ii) the part of the lump sum (if any) that is attributable to amounts transferred into the fund from any other *foreign superannuation fund during the period;
(b) subtract that total amount from the amount in the fund that was vested in you when the lump sum was paid (before any deduction for *foreign income tax); (c) add the total of all your previously exempt fund earnings (if any) covered by subsections (5) and (6). Subsection 305-75(3) of the ITAA 1997 states, if you become an Australian resident after the start of the period to which the lump sum relates (but before you receive it), the amount of your applicable fund earningsis the amount (not less than zero) worked out as follows: (a) work out the total of the following amounts: (i) the amount in the fund that was vested in you just before the day (the start day ) you first became an Australian resident during the period; (ii) the part of the payment that is attributable to contributions to the fund made by or in respect of you during the remainder of the period; (iii) the part of the payment (if any) that is attributable to amounts transferred into the fund from any other *foreign superannuation fund during the remainder of the period;
(b) subtract that total amount from the amount in the fund that was vested in you when the lump sum was paid (before any deduction for *foreign tax); (c) multiply the resulting amount by the proportion of the total days during the period when you were an Australian resident; (d) add the total of all previously exempt fund earnings (if any) covered by subsections (5) and (6). The effect of section 305-75 of the ITAA 1997 is that only the income earned in respect of the foreign superannuation fund since Australian residency, less any contributions made in that period, is assessed. Further, amounts representing earnings accrued during periods of non-residency, as well as amounts arising from transfers into the paying fund, do not form part of the taxable amount when the lump sum is paid. Previously exempt fund earnings
An amount of applicable fund earnings may also include amounts of previously exempt fund earnings which occur where an amount in a foreign super fund is transferred to another foreign super fund before being received in Australia. These earnings would not otherwise be included and are set aside until the lump sum is transferred to the individual taxpayer, or to their complying Australian super fund. Whether you have an amount of previously exempt fund earnings in respect of a later lump sum is determined under subsection 305-75(5) and subsection 305-75(6) of the ITAA 1997. Subsections 305-75(5) and (6) of the ITAA 1997 state: (5) You have an amount of previously exempt fund earnings in respect of the lump sum if: (a) part or all of the amount in the fund that was vested in you when the lump sum was paid (before any deduction for *foreign income tax) is attributable to the amount; and (b) the amount is attributable to a payment received from a *foreign superannuation fund; and (c) the amount would have been included in your assessable income under subsection 305-70(2)
by the application of this section, but for the payment having been received by another foreign superannuation fund. (6) The amount of your previously exempt fund earnings is the amount mentioned in paragraph (5)(c) (disregarding the addition of previously exempt fund earnings under subsection (2) or (3) of this section). Subsection 305-75(5) of the ITAA 1997 identifies whether you have an amount of previously exempt fund earnings. That may arise where there is an amount in respect of the lump sum being paid by a foreign superannuation fund, which had previously been paid into that fund from another foreign superannuation fund, and would have been included in your assessable income under subsection 305-70(2) of the ITAA 1997 but for it being received by a foreign superannuation fund.
Subsection 305-75(6) of the ITAA 1997 states that the amount of previously exempt fund earnings is the amount mentioned in paragraph 305-75(5)(c), though disregards the addition of previously exempt fund earnings under subsection 305-75(2) or (3). The requirement to disregard the addition of earlier applications of subsection 305-75(6) of the ITAA 1997 ensures that amounts of previously exempt fund earnings are not duplicated. Multiple lump sum payments Where multiple lump sums have been paid to you from the same foreign superannuation fund, then subsection 305-75(4) of the ITAA 1997 provides a modification to the calculation of applicable fund earnings. The subsection provides: If the lump sum is not the first lump sum from the fund you have received to which this section applies, for subsections (2) and (3) the start day is the day after you received the most recent such lump sum.
Accordingly, where you are an Australian resident at all times during the period to which a lump sum relates, and the lump sum is not the first lump sum paid from the fund, then subsection 305-75(4) of the ITAA 1997 modifies the applicable fund earnings calculation under subsection 305-75(2) of the ITAA 1997. In particular, the 'start date' in paragraph 305-75(2)(a)(i) of the ITAA 1997 for the purpose of calculating contributions made by or in respect of you, is modified to the day after you received the most recent lump sum. Also, where you are not an Australian resident at all times during the period to which a lump sum relates, and the lump sum is not the first lump sum paid from the fund then subsection 305-75(4) of the ITAA 1997 modifies the applicable fund earnings calculation under subsection 305-75(3) of the ITAA 1997. Similarly, the 'start date' in paragraph 305-75(3)(a)(i) of the ITAA 1997 for the purpose of calculating the amount vested in you just before you first became an Australian resident during the period, is modified to the day after you received the most recent lump sum. Foreign currency conversion
The foreign currency translation rules for lump sums paid by foreign superannuation funds are explained in ATO Interpretative Decision ATO ID 2015/7: Foreign currency translation rules in working out 'applicable fund earnings' under section 305-75 of the ITAA 1997 (ATO ID 2015/7). For the purposes of working out your applicable fund earnings in relation to a superannuation lump sum under section 305-75 of the ITAA 1997, the correct rule for translating foreign currency into Australian dollars is the rule described in Item 11A of the table in subsection 960-50(6) of the ITAA 1997 (as modified by regulation 960-50.01(1) of the Income Tax Assessment (1997 Act) Regulations 2021 ).
This means that the exchange rate at which it is reasonable to translate amounts into Australian currency for the purposes of section 305-75 of the ITAA 1997, is the exchange rate applicable at the time of receipt of the relevant superannuation lump sum directly by you or your complying superannuation fund. Specifically, under subsection 960-50(4) of the ITAA 1997, each amount or component that is denoted in a foreign currency must be translated into an Australian dollar equivalent first before any calculations are undertaken. Applicable fund earnings choice You may decide to pay your superannuation lump sum into your complying superannuation fund. If you do so, you may also choose to have all or part of your applicable fund earnings in respect of the lump sum included in the assessable income of the fund. Correspondingly, the amount of applicable fund earnings that would otherwise be included in your assessable income is then reduced by the applicable fund earnings chosen to be assessable in the fund.
You can make a choice, where section 305-70 of the ITAA 1997 applies, for applicable fund earnings to be included in the assessable income of your complying superannuation fund where: • you are taken to have received the lump sum under section 307-15 of the ITAA 1997; and • the whole of the lump sum is paid into a complying superannuation fund; and • immediately after the lump sum is paid you no longer have a superannuation interest in the foreign superannuation fund. You must make your choice in writing. You have done this by completing the form Completing your choice to have your Australian super fund pay tax on a foreign super transfer (NAT 11724). Your concessional contributions exclude applicable fund earnings that are included in the complying superannuation fund's assessable income due to a choice made under section 305-80 of the ITAA 1997. Any amount of the lump sum that is not included in the fund's assessable income as applicable fund earnings will be a non-concessional contribution of the fund. Applicable fund earnings calculation Transfer 1: Fund A to Fund C
As you became a member of Fund A before you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(3) of the ITAA 1997. Fund A and Fund C are both foreign superannuation funds, and on that basis any part of the lump sum paid by Fund A to Fund C is not assessable income and is not exempt income under subsection 305-70(4) of the ITAA 1997. However, an amount of previously exempt fund earnings may arise in relation to the lump sum under subsections 305-75(5) and 305-75(6) of the ITAA 1997. Such amounts may be included in the applicable fund earnings calculations in relation to a later lump sum payment by Fund C. Table 1:Earnings calculations in relation to a later lump sum payment by Fund C Item Description Amount in (£pound;) A Amount in fund vested in the taxpayer on the day just before the residency date (9 August 2012) £pound;XXX B Part of the payment attributable to contributions to the Fund during the remainder of the period £pound;0 C Part of the payment attributable to amounts transferred into the fund from any other foreign superannuation funds during the remainder of the period £pound;0 D
A + B + C (The step outlined in paragraph 305-75(3)(a) of the ITAA 1997) Not applicable E Amount in the fund vested in the taxpayer when the lump sum was transferred £pound;XXX F E - D (The step outlined in paragraph 305-75(3)(b)) Not applicable G The proportion of the total days during the period of which the taxpayer was an Australian resident for tax purposes. Not applicable H Previously exempt fund earnings (if any) Not applicable I F x G + H = Applicable Fund Earnings (as future previously exempt fund earnings) Not applicable Transfer 2: Fund C to Fund D As you became a member of Fund C after you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. As Fund D is a foreign superannuation fund, any part of the lump sum paid by Fund C to Fund D is not assessable income and is not exempt income under subsection 305-70(4) of the ITAA 1997.
However, an amount of previously exempt fund earnings may arise in relation to the lump sum under subsections 305-75(5) and 305-75(6) of the ITAA 1997. Such amounts may be included in the applicable fund earnings calculations in relation to a later lump sum payment by Fund D. Table 2: Earnings calculations in relation to a later lump sum payment by Fund D Item Description Amount in (£pound;) A Part of the lump sum attributable to contributions to the fund £pound;0 B Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX C A + B Not applicable D Amount in fund vested in taxpayer when the lump sum was transferred £pound;XXX E D - C Not applicable F All previously exempt fund earnings (if any) £pound;XXX G E + F = Applicable Fund Earnings (as future previously exempt fund earnings) Not applicable Transfer 3: Fund B to Fund C As you became a member of Fund B before you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(3) of the ITAA 1997.
As Fund C is a foreign superannuation fund, any part of the lump sum paid by Fund B to Fund C is not assessable income and is not exempt income under subsection 305-70(4) of the ITAA 1997. However, an amount of previously exempt fund earnings may arise in relation to the lump sum under subsections 305-75(5) and 305-75(6) of the ITAA 1997. Such amounts may be included in the applicable fund earnings calculations in relation to a later lump sum payment by Fund E. Table 3: Earnings calculations in relation to a later lump sum payment by Fund E. Item Description Amount in (£pound;) A Amount in fund vested in the taxpayer on the day just before the residency date (9 August 2012) £pound;XXX B Part of the payment attributable to contributions to the Fund during the remainder of the period £pound;0 C Part of the payment attributable to amounts transferred into the fund from any other foreign superannuation funds during the remainder of the period £pound;0 D A + B + C (The step outlined in paragraph 305-75(3)(a) of the ITAA 1997) Not applicable E Amount in the fund vested in the taxpayer when the lump sum was transferred £pound;XXX F E - D (The step outlined in paragraph 305-75(3)(b))
£pound;XXX G The proportion of the total days during the period of which the taxpayer was an Australian resident for tax purposes. Not applicable H Previously exempt fund earnings (if any) Not applicable I F x G + H = Applicable Fund Earnings (as future previously exempt fund earnings) Not applicable Transfer 4: Fund C to Fund D As you became a member of Fund C after you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. As Fund D is a foreign superannuation fund, any part of the lump sum paid by Fund C to Fund D is not assessable income and is not exempt income under subsection 305-70(4) of the ITAA 1997. However, an amount of previously exempt fund earnings may arise in relation to the lump sum under subsections 305-75(5) and 305-75(6) of the ITAA 1997. Such amounts may be included in the applicable fund earnings calculations in relation to a later lump sum payment by Fund D. Table 4: Earnings calculations in relation to a later lump sum payment by Fund D. Item Description Amount in (£pound;) A
Part of the lump sum attributable to contributions to the Fund during the remainder of the period £pound;0 B Part of the payment attributable to amounts transferred into the fund from any other foreign superannuation funds during the remainder of the period £pound;XXX C A + B (The step outlined in paragraph 305-75(3)(a) of the ITAA 1997) £pound;XXX D Amount in the fund vested in the taxpayer when the lump sum was transferred £pound;XXX F Previously exempt fund earnings (if any) £pound;XXX G E + F = Applicable Fund Earnings (as future previously exempt fund earnings) Not applicable Transfer 5: Fund D to Fund E As you became a member of Fund D after you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. As Fund E is a foreign superannuation fund, any part of the lump sum paid by Fund D to Fund E is not assessable income and is not exempt income under subsection 305-70(4) of the ITAA 1997.
However, an amount of previously exempt fund earnings may arise in relation to the lump sum under subsections 305-75(5) and 305-75(6) of the ITAA 1997. Such amounts may be included in the applicable fund earnings calculations in relation to a later lump sum payment by Fund F. Table 5: Earnings calculations in relation to a later lump sum payment by Fund F. Item Description Amount in (£pound;) A Part of the lump sum attributable to contributions to the fund £pound;0 B Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX C A + B £pound;XXX D Amount in fund vested in you when the lump sum was transferred £pound;XXX E D - C £pound;XXX F All previously exempt fund earnings (if any) £pound;XXX G E + F = Applicable Fund Earnings (as future previously exempt fund earnings, limited by the lump sum payment) £pound;XXX Transfer 6: Fund D to Fund E As you became a member of Fund D after you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997.
As Fund E is a foreign superannuation fund, any part of the lump sum paid by Fund D to Fund E is not assessable income and is not exempt income under subsection 305-70(4) of the ITAA 1997. However, an amount of previously exempt fund earnings may arise in relation to the lump sum under subsections 305-75(5) and 305-75(6) of the ITAA 1997. Such amounts may be included in the applicable fund earnings calculations in relation to a later lump sum payment by Fund F. Table 6: Earnings calculations in relation to a later lump sum payment by Fund F. Item Description Amount in (£pound;) A Part of the lump sum attributable to contributions to the fund £pound;0 B Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX C A + B £pound;XXX D Amount in fund vested in you when the lump sum was transferred £pound;XXX E D - C £pound;XXX F All previously exempt fund earnings (if any) Not applicable G E + F = Applicable Fund Earnings (as future previously exempt fund earnings, limited by the lump sum payment) £pound;XXX Transfer 7: Fund D to you
As you became a member of Fund D after you became a resident of Australia, applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. Any amounts in pounds sterling are translated into Australian dollars using the exchange rate applicable on the date of receipt of the relevant superannuation lump sum directly by you on XX XX XXXX. In this case, the relevant exchange rate was AUD $1 = £pound;0.XXXX. Table 7: Amounts in pounds sterling are translated into Australian dollars using the exchange rate Fund D. Item Description Amount in (£pound;) Amount in ($) $1 = £pound;0.XXXX A Part of the lump sum attributable to contributions to the fund £pound;0 $0 B Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX $XXX C A + B £pound;XXX $XXX D Amount in fund vested in you when the lump sum was transferred £pound;XXX $XXX E D - C £pound;XXX $XXX F All previously exempt fund earnings (if any) Not applicable $0 G E + F = Applicable Fund Earnings £pound;XXX $XXX H Applicable Fund Earnings attributable to lump sum payment £pound;XXX $XXX
The applicable fund earnings amount in respect of the lump sum paid to you from Fund D during the 2025 income year is $XXX,XXX.XX. Transfer 8: Fund E to SMSF As you became a member of Fund E after you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. As the SMSF is a complying superannuation fund, you may choose an amount of your applicable fund earnings worked out under section 305-75 of the ITAA 1997 to be included in the assessable income of the fund under subsection 305-80(2) of the ITAA 1997. Any amounts in pounds sterling are translated into Australian dollars using the exchange rate applicable on the date of receipt of the relevant superannuation lump sum directly by your complying superannuation fund on XX XX XXXX. In this case, the relevant exchange rate was AUD $1 = £pound;0.XXXX. Table 8: Amounts in pounds sterling are translated into Australian dollars using the exchange rate Fund E. Item Description Amount in (£pound;) Amount in ($) $1 = £pound;0.XXXX A Part of the lump sum attributable to contributions to the fund £pound;0 $0 B
Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX $XXX C A + B £pound;XXX $XXX D Amount in fund vested in taxpayer when the lump sum was transferred £pound;XXX $XXX E D - C £pound;XXX $XXX F All previously exempt fund earnings (if any) £pound;XXX $XXX G E + F = Applicable Fund Earnings £pound;XXX $XXX H Applicable Fund Earnings attributable to lump sum payment £pound;XXX $XXX For the purposes of item F in the table, the amount reflects the applicable fund earnings (as future previously exempt fund earnings) in relation to the transfer from Fund D into Fund E and translated using the exchange rate applicable on the date that the lump sum is paid into Australia. The amount you chose as applicable fund earnings on the form Completing your choice to have your Australian super fund pay tax on a foreign super transfer will be included in the SMSF's assessable income. Any remaining applicable funds earnings not covered by your choice will be included in your own assessable income. The applicable funds earnings amount in respect of the transfer from Fund E to the SMSF during the 2025 income year is $XX,XXX.XX. Transfer 9: Fund D to you
As you became a member of Fund D after you became a resident of Australia, applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. Any amounts in pounds sterling are translated into Australian dollars using the exchange rate applicable on the date of receipt of the relevant superannuation lump sum directly by you on XX XX XXXX. In this case, the relevant exchange rate is AUD $1 = £pound;0.XXXX. Table 9: Amounts in pounds sterling are translated into Australian dollars using the exchange rate Fund D to you. Item Description Amount in (£pound;) Amount in ($) $1 = £pound;0.XXXX A Part of the lump sum attributable to contributions to the fund £pound;0 $0 B Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX $XXX C A + B £pound;XXX $XXX D Amount in fund vested in you when the lump sum was transferred £pound;XXX $XXX E D - C £pound;XXX $XXX F All previously exempt fund earnings (if any) Not applicable $0 G E + F = Applicable Fund Earnings £pound;XXX $XXX H Applicable Fund Earnings attributable to lump sum payment £pound;XXX $XXX
The applicable fund earnings amount in respect of the lump sum paid to you from Fund D during the 2025 income year is $XX,XXX.XX. Transfer 10: Fund D to you As you became a member of Fund D after you became a resident of Australia, applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. Any amounts in pounds sterling are translated into Australian dollars using the exchange rate applicable on the date of receipt of the relevant superannuation lump sum directly by you on XX XX XXXX. In this case, the relevant exchange rate is AUD $1 = £pound;0.XXXX. Table 10: Amounts in pounds sterling are translated into Australian dollars using the exchange rate Fund D to you. Item Description Amount in (£pound;) Amount in ($) $1 = £pound;0.XXXX A Part of the lump sum attributable to contributions to the fund £pound;0 $0 B Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX $XXX C A + B £pound;XXX $XXX D Amount in fund vested in you when the lump sum was transferred £pound;XXX $XXX E D - C £pound;XXX $XXX F All previously exempt fund earnings (if any) Not applicable $0 G E + F
= Applicable Fund Earnings £pound;XXX $XXX H Applicable Fund Earnings attributable to lump sum payment £pound;XXX $XXX The applicable fund earnings amount in respect of the lump sum paid to you from Fund D during the 2025 income year is $XX,XXX.XX. Transfer 11: Fund D to SMSF2 As you became a member of Fund D after you became a resident of Australia, the applicable fund earnings on this lump sum will be worked out in accordance with subsection 305-75(2) of the ITAA 1997. As SMSF2 is a complying superannuation fund, you may choose an amount of your applicable fund earnings worked out under section 305-75 of the ITAA 1997 to be included in the assessable income of the fund under subsection 305-80(2) of the ITAA 1997. Any amounts in pounds sterling are translated into Australian dollars using the exchange rate applicable on the date of receipt of the relevant superannuation lump sum directly by your complying superannuation fund on XX XX XXXX. In this case, the relevant exchange rate was AUD $1 = £pound;0.XXXX. Table 11: Amounts in pounds sterling are translated into Australian dollars using the exchange rate Fund D to SMSF2 Item Description Amount in (£pound;) Amount in ($)
$1 = £pound;0.XXXX A Part of the lump sum attributable to contributions to the fund £pound;0 $0 B Part of the lump sum attributable to amounts transferred from foreign funds into the fund £pound;XXX $XXX C A + B £pound;XXX $XXX D Amount in fund vested in taxpayer when the lump sum was transferred £pound;XXX $XXX E D - C £pound;XXX $XXX F All previously exempt fund earnings (if any) £pound;XXX $XXX G E + F = Applicable Fund Earnings £pound;XXX $XXX H Applicable Fund Earnings attributable to lump sum payment £pound;XXX $XXX The amount you chose as applicable fund earnings on the form Completing your choice to have your Australian super fund pay tax on a foreign super transfer will be included in the SMSF's assessable income. Any remaining applicable funds earnings not covered by your choice will be included in your own assessable income. The applicable funds earnings amount in respect of the transfer from Fund D to SMSF2 during the 2025 income year is $XX,XXX.XX.