SMSFs must remain an Australian super fund to maintain concessional tax treatment. This requires passing the residency tests:
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The fund must be established in Australia,
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Central management and control must remain in Australia,
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Active members must hold at least 50% of fund balances.
If all members move overseas permanently, the SMSF will likely fail the residency tests and could be taxed at 45% on its income. Often, members in this situation roll their benefits into a retail or industry fund before leaving.