Highlights

  • Bryce Figot of DBA Lawyers identifies a practical 90-day rule for SMSF valuation evidence timing.
  • The ATO valuation guide sets no fixed age limit for evidence but requires it to be objective, supportable and current.
  • A single item of evidence alone is insufficient; trustees should gather multiple supporting sources.
  • A qualified independent valuer is only mandatory in a limited set of specific circumstances under ATO guidance.

Getting SMSF asset valuations right is one of the most examined areas in fund audits. The ATO's valuation guidance sets clear quality standards without specifying rigid timeframes, but practitioners have identified practical thresholds trustees should understand.

The 90-Day Practical Rule

Bryce Figot of DBA Lawyers has identified a 90-day benchmark for valuation evidence timing. While the ATO's official guide does not set a fixed age limit, evidence that is more than 90 days old at the relevant measurement date faces greater scrutiny during audits over whether it remains sufficiently current.

The guide's actual requirement is that evidence be objective, supportable, and current as at the valuation date. Current means it reflects conditions at the time of measurement, not historical conditions that may no longer apply to the asset.

What Makes Evidence Acceptable

The ATO expects valuation evidence to be objective, meaning it does not rely solely on the trustee's own judgment. It should be supportable with documentation that another party can review and verify. A bare assertion from the trustee or a single undocumented estimate does not meet this standard.

Crucially, one item of evidence alone is insufficient. Trustees should gather multiple sources to triangulate the value. For real property, this might include recent comparable sales, a council rate notice, and a real estate agent's appraisal. For unlisted shares, financial statements combined with comparable transaction data strengthen the file.

When an Independent Valuer Is Required

The ATO guide mandates a qualified independent valuer only in limited, specific circumstances. These do not apply to all asset valuations. For most assets, trustees can produce acceptable evidence through other documented means without engaging a registered valuer, provided the evidence is objective, supportable, and current.

However, where an independent valuer is required, the fund must engage one who holds appropriate qualifications. Substituting informal estimates or internal assessments in those circumstances creates compliance exposure at audit.