Valuing Unlisted SMSF Assets for Illawarra Trustees and Auditors

Dated, reasoned market values that your SMSF auditor can follow and accept, for the fund assets with no screen price: shares in the family company, units in a related trust, a Unanderra workshop or Dapto factory unit leased to the members' business, and loans to related parties.

Indicative valuations from A$799. Certified Summary and Detailed reports from seven business days.

An SMSF must show its assets at market value at 30 June and keep objective, supportable evidence behind each figure. Where an asset has no quoted price, such as private company shares, related trust units, premises leased to the members' business or a loan, Illawarra trustees need a dated valuation from someone independent of the fund.

Why SMSF auditors ask for more than a figure

An SMSF auditor signs two opinions each year, one on the financial statements and one on compliance with superannuation law, and both rest on asset values. Listed shares and cash can be checked against a statement in minutes. A slice of the members' own business is different: the auditor must be satisfied that the number in the accounts is a market value and not a hopeful guess, and the trustees carry the job of showing it.

Funds run by Illawarra business families tend to hold a recognisable set of hard-to-value assets. An industrial unit in the Unanderra, Dapto or Port Kembla areas leased to the members' trade or engineering company. A shop or office near Crown Street let to the family's own practice. A holiday rental or cafe premises at Kiama or Shellharbour. A minority interest in a North Wollongong professional firm, units in a trust that owns commercial property, or a loan to a relative's company. Each one calls for a method, evidence and valuation date suited to why the figure is needed.

That figure travels further than most trustees expect. It feeds into each member's total superannuation balance, which governs contribution caps and Division 296. It sets the transfer balance credit when a retirement phase pension starts, and with it that year's minimum payment. It determines whether the fund stays inside the 5 per cent in-house asset limit. If a related-party price strays from market, the non-arm's length income rules can tax the affected income at the top rate.

We value the unlisted assets auditors question most, dated to whatever event needs the number. Trustees decide, the accountant prepares the accounts and the auditor applies the law; our job is to supply a value with its reasoning laid out so each of them can rely on it.

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Andrew Mackson
Andrew Mackson, CFA, ABV, CBV
Managing Partner · 15+ years
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What triggers an SMSF valuation, and what evidence satisfies an auditor

Regulation 8.02B of the Superannuation Industry (Supervision) Regulations 1994 requires an SMSF to prepare its financial statements with assets stated at market value. The ATO's guidance on valuing SMSF assets looks for objective, supportable evidence prepared by someone with suitable skills and refreshed when circumstances change. A full formal valuation is not needed for every asset every year; in between, a recorded review confirming that nothing material has moved may do.

Every 30 June

The annual statements show each asset at market value on the last day of the year. A figure rolled forward unchanged, with no sign of review, prompts questions, and if the auditor cannot be satisfied about a material asset the audit report has to be qualified and a contravention report to the ATO may follow.

The day a pension starts

Fund assets valued on the commencement day set the credit to the member's transfer balance account and the starting point for the minimum annual payment. Both are awkward to correct after reporting, so when an unlisted asset supports the pension it makes sense to have it valued as at that day.

Related-party transactions

A fund may acquire only limited classes of asset from a related party, business real property being one, and must pay market value; a disposal to a related party must also be at arm's length. Moving a Port Kembla factory or a Dapto commercial unit into the fund, or selling family company shares out of it, calls for a valuation dated to the transfer. Where duty applies to a property transfer, value matters for that purpose as well, so one piece of evidence can often serve both.

Events between balance dates

Benefit payments and rollovers, a switch from accumulation to retirement phase, a wind up, and anything else that could move a value materially before the next 30 June: the anchor tenant leaving a suburban shopping centre, an investee company losing a key contract, a seasonal downturn hitting a tourism tenant at Kiama, or the death of a member.

Division 296 and values at 30 June 2026

Division 296 imposes extra tax on the earnings that relate to the part of a member's total superannuation balance sitting over its threshold, and the first balances to be measured are those at 30 June 2026. A fund holding property, private company shares or unlisted trust units on that day needs a market value for each as at 30 June 2026, even if none was commissioned when the date passed. A valuation prepared today can address that date, as long as it draws only on facts known or reasonably knowable then. The same number can serve again if the fund's adviser proposes resetting the cost base of fund assets to their 30 June 2026 values. The thresholds, rates and elections for each member are for your adviser to confirm; we provide the values.

Choosing the method to suit each asset

An auditor's first question is whether the method fits the asset, so our report starts there too. A company holding only cash and listed securities can be valued on net assets. A trading company cannot, because the goodwill a buyer would pay for its earnings is absent from its balance sheet.

Private company shares and units in a trading trust are valued under the income approach: normalised maintainable earnings capitalised at a rate reflecting risk, tested against sales evidence, with net assets as the floor. Where the fund holds less than control, the report asks whether the facts, including the shareholders' agreement and dividend history, support a discount for lack of control or marketability, and explains the answer. A discount taken by habit fails review just as surely as one nobody considered.

Business real property leased to the members' business needs a capital value and a market rent, and rent is where support most often goes missing. Leasing evidence can usually be found across the industrial areas of Unanderra, Dapto, Port Kembla and Albion Park Rail, and around the Wollongong CBD and North Wollongong commercial areas; where the capital value is material, a registered property valuer's report sits behind it. Units in a related unit trust are valued alongside the trust's underlying assets at the same date, and we confirm the trust still meets the conditions that keep the units outside the in-house asset limit. Loans are tested on whether the borrower can truly repay, what security supports the debt and whether an unrelated lender would accept its terms. Collectables have their own regulation, including the need for a qualified independent valuer when one is sold to a related party.

What goes into the audit file

Why auditors query or qualify SMSF values

Auditors keep finding the same gaps. Any of them can produce a qualified audit report or a contravention report, and each is prevented by a fitting method applied at the right date.

Report Types and Pricing: Valuations From A$799

The fund's auditor reads an SMSF valuation every year, and the ATO reads one now and then. A certified Summary report usually serves, since the method, evidence and reasoning are on the page and the auditor does not need our working papers. The Detailed report earns its extra depth when a related-party transfer is large, a pension is starting on a significant unlisted asset, or a member's Division 296 balance at 30 June 2026 turns on the result.

Indicative Valuation
From A$799
Choose this if the trustees still have a decision ahead, such as when to start a pension, whether to move an asset into or out of the fund, or what Division 296 might mean for a member, and want a reasoned range before anything is audited or lodged. Intended for internal decision-making; it is not a certified opinion for lenders, courts or the ATO.
Delivery: from seven business days after receipt of all information
Up to 50 pages
Internal audience
Can be used in litigation
Capital structure: common equity, bank/shareholder loans
Compliant with ATO market value guidance
APES 225 Valuation Engagement
Certified and signed by an experienced practitioner
Completed and reviewed by well trained staff
Considers and applies, when relevant, all 3 valuation approaches (income, market, asset)
Applies multiple cost of capital estimates (limited to 3)
Executive summary
Statement of limiting conditions
Valuation exhibits
Glossary
Table of contents
Company review
Industry review
Economic review
Discussion of valuation approaches and types of discounts
Discussion of the application of valuation approaches and discounts
Conclusion
Email support
Closing Zoom Call
Detailed Valuation
Contact for Pricing
Choose this if the asset is big enough to attract ATO interest, an earlier audit was qualified, or the figure may later have to hold up in a sale, a family dispute or the administration of an estate. Certified and signed. Applies and reconciles all relevant approaches in full so another expert can follow the reasoning.
Delivery: from seven business days after receipt of all information
150+ pages
Internal and external audience, including for litigation or when likely to be reviewed by others
Can be used in litigation by a broad range of professionals
Capital structure: common equity, bank/shareholder loans
Compliant with ATO market value guidance
APES 225 Valuation Engagement
Certified and signed by an experienced practitioner
Completed and reviewed by well trained staff
Considers and applies, when relevant, all 3 valuation approaches (income, market, asset)
Applies multiple cost of capital estimates (full set of 12)
Executive summary
Statement of limiting conditions
Valuation exhibits
Glossary
Table of contents
Company review (full)
Industry review (full)
Economic review (full)
Discussion of valuation approaches and types of discounts (full)
Discussion of the application of valuation approaches and discounts (full)
Conclusion
Email support
Closing Zoom Call

See the full Services and Pricing page

What the report contains and who answers for it

The report opens with the event that triggered it, the valuation date, the standard of value and the documents relied on, then values each asset by the method suited to it. A trading company is supported by a normalisation schedule, maintainable earnings and a capitalisation rate, all sourced. Leased premises are supported by sales and rental evidence side by side. The reconciliation shows how the conclusion was reached so the auditor can follow it unaided, though we are glad to take the call.

A certified valuer with no stake in the fund, its members or the valued entities signs each report, answers the auditor's queries and defends the opinion if the ATO reviews the fund. That independence is much of what the auditor relies on, and it is why a short letter from the fund's own accountant rarely settles the matter. If the same asset is contested later, for example in a family provision claim under the Succession Act 2006 (NSW) or a shareholder dispute before the Supreme Court of New South Wales, the valuer who signed the SMSF report can explain the figure.

One question for every trustee

Pick the largest asset in the fund with no quoted price. If the auditor asked for its evidence next week, would you hand over a dated, reasoned report from someone who gains nothing from the number, or a figure copied from last year? If it is the second, begin with that asset.

What Wollongong trustees and accountants ask about SMSF valuations

No. Every asset is reported at market value at 30 June, but the evidence differs by type. A broker or platform statement supports listed shares, managed funds and cash. Private company shares, related trust units, real property, loans and collectables need a documented valuation, either a current one or one backed by a reasoned review confirming nothing material has changed. The test is whether the auditor can accept the evidence without qualifying the audit report.
A valuer who gains nothing from the result, a method suited to the asset, sourced inputs, and a valuation date matching 30 June or the event that needed the figure. Queries usually arise where a trading company was valued on net assets, a property figure came from a rates notice, or a brief letter came from the members' own accountant. If a material asset still cannot be supported, the audit report is qualified and the auditor may have to lodge an auditor contravention report with the ATO.
Both the property and the rent. Trustees tend to focus on capital value, but a lease to the members' company has to be on arm's length terms, so the rent must be compared with market rents for similar space nearby, whether an industrial unit at Unanderra or Dapto, or a yard near Port Kembla. A below-market rent means the arm's length requirement is not met however well the capital value is supported; an above-market rent raises contribution issues.
Only if the company is purely an investment holding vehicle. A trading company has goodwill that its balance sheet does not show, so net assets understate its worth. The auditor and the ATO will both expect a trading business to be valued on sustainable earnings, tested against comparable sales, with net assets as the minimum. For a minority stake the report should consider whether the facts support a discount for lack of control or marketability, instead of applying one by default or ignoring the question.
The value on that day drives two calculations: the credit to the member's transfer balance account and that year's minimum pension payment. If the figure proves wrong, the member may have exceeded the cap or the pension may have been underpaid, and substituting a different number later cures neither. A valuation dated to the first day of the pension avoids the argument.
Usually, yes. Division 296 adds tax on earnings linked to the part of a member's total superannuation balance above its threshold, and balances are first measured at 30 June 2026. For property, private company shares or unlisted trust units, the market value at that date feeds into the member's balance and may also matter if the adviser recommends a cost base reset. A valuation can still be prepared today as at that date, so long as it relies only on what was known then. Your adviser confirms each member's thresholds and elections, and we supply the values.
Certified reports are delivered from seven business days after we receive the fund's documents, whether the asset is in the Wollongong CBD, Dapto or Kiama. For a company, send three to five years of financial statements and tax returns plus the share register; for property, the lease and any earlier valuations; for a unit trust, the deed and accounts; for a loan, the agreement and the repayment record. When the fund holds several unlisted assets, valuing them all at one date is quicker and keeps the figures consistent. An Indicative valuation built on the same analysis is for internal decision-making only and is not evidence an auditor will rely on.
Indicative valuations start from A$799 and are intended for internal decision-making, so they suit an owner who wants a well-reasoned range before committing to anything. Summary and Detailed reports are certified and are quoted after a free consultation, because the fee depends on the purpose, the number of entities, the state of the records and whether the opinion must withstand review by a court, the ATO or another expert. The fee is confirmed in the engagement letter before work starts, and every report is delivered from seven business days after we receive the information.

Book a Free Consultation

Talk your situation through with a certified valuer before you commit to anything, at no cost.

Andrew Mackson
Andrew Mackson, CFA, ABV, CBV
Managing Partner · 15+ years
Book a Free Consultation →

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