On balance CA ANZ does not support the policy measure contained in the Exposure Draft for a large number of reasons including:

• The complex design features of the policy which will add considerable cost to administer the whole superannuation system
• It alters the tax mix for those already retired and those saving for retirement when certainty is essential; otherwise it is inevitable that many will be discouraged from making adequate contributions towards their retirement
• We question how much net revenue will be raised from this measure
• We believe there may be better solutions available to the government
• The current design of the policy taxes unrealised gains which shows this is likely to cause many funds cash flow concerns.