Key Highlights

•  Trustees should identify every liability first, including final invoices, PAYG instalments, PAYG withholding and capital gains tax.

•  The ATO recommends checking the fund's account balances, claiming refunds such as excess franking credits and leaving a buffer for post-lodgment costs.

•  The bank account should be closed only after liabilities are paid, refunds received, rollovers complete and the ATO has confirmed the wind-up in writing.

Closing a self-managed super fund's bank account can feel like the moment the job is done. In reality, it should be one of the very last steps. ATO guidance is clear that a fund cannot be closed while it still has credit or debit balances, and an account closed too early can leave a refund with nowhere to go and the wind-up stuck in limbo.

For trustees, the practical lesson is to treat the fund's tax position, its supervisory levy and its banking arrangements as one connected checklist rather than separate tasks.

Identify every liability first

The ATO's wind-up guidance lists the amounts trustees need to pay before closing a fund. They include final invoices from service providers, the costs of selling assets, PAYG instalments, PAYG withholding and capital gains tax. Trustees should also check whether the fund has any GST or business activity statement obligations.

Some liabilities are easy to overlook. A fund that paid a pension may have PAYG withholding reporting to complete, including payment summaries for income streams or lump sums and an annual report where tax was withheld during the year. The ATO asks for these to be lodged promptly because it uses them to pre-fill members' tax returns.

Check the fund's ATO accounts and claim refunds

The ATO recommends checking the fund's account balances through Online services for business, by contacting the ATO or through a tax professional, and requesting any refunds due. Common sources of refunds include excess franking credits and PAYG instalments that exceed the fund's final tax liability.

Where a fund receives a refund it is not entitled to keep, such as an amount that belongs to a member who has already rolled out, the ATO says it should be rolled over through SuperStream immediately, before the ABN is cancelled. Leaving such amounts sitting in the account creates a problem that is difficult to fix once the fund's registration has ended.

Understand the final-year supervisory levy

The supervisory levy is paid in advance. According to the ATO's levy guidance, the levy has been $259 a year since 2014–15, and continuing funds pay it for the following financial year when they lodge.

For a fund that is winding up, the position is different. If the fund is not newly registered and paid the levy in the previous year, no further levy is required, because the current year is already covered. A newly registered fund that winds up in its first year pays $259 for that year. The adjustment is made in the final annual return at the supervisory levy question, using the table in the relevant year's return instructions.

Leave a buffer for post-lodgment costs

The ATO advises trustees to leave enough money in the fund to meet costs that arise after the final return is lodged, such as professional fees, audit fees and tax. Trustees who roll out every dollar and then receive an accountant's invoice or a small tax assessment may find the fund has no means of paying it, which can delay ATO confirmation of the wind-up.

Review direct debits and recurring payments

Recurring arrangements are another source of loose ends. Before the account is closed, trustees should cancel or redirect direct debits for investment platforms, software subscriptions, insurance premiums and property expenses, and tell contributing employers that the fund is closing. The ATO's guidance specifically lists employers, the tax agent, the auditor and any financial adviser as third parties to notify.

When the account can be closed

The ATO says the bank account should be closed only after:

  • all final liabilities have been paid;
  • all final refunds have been received, having confirmed the ATO holds the correct bank details;
  • rollovers have been completed through SuperStream; and
  • the ATO has confirmed in writing that the fund has been wound up.

The ATO's auditor guidance adds that if the account stays open after the audit to pay final tax or receive a refund, the auditor should obtain written representations that later transactions will comply with super law. The audit report may be qualified for that reason.

Hypothetical example

A hypothetical fund completes its final rollover in April and lodges its final return in June, showing a refund of excess franking credits. The trustees have kept the account open and confirmed that the ATO holds the correct bank details. When the refund arrives, the trustees roll it to the members' new fund through SuperStream, pay the final accounting invoice from the buffer they retained and then close the account after receiving the ATO's confirmation letter.

Takeaway

The bank account is the fund's last line of communication with the ATO and its service providers. Trustees who list every liability, claim refunds, understand the final-year levy rules, keep a modest buffer and close the account only after the ATO confirms the wind-up can avoid the most common causes of delay.