If I have read all the posts and articles correctly it appears that under 27CAA superannuation can be transferred into Australia (say after 2 years) and taxed in the Australian Superanuuation Fund (at 15%)
Questions: (1) If the Foreign country applies a non-refundable withholding tax prior to the transfer is there a foreign tax credit applicable in Australia?
(2) If an individual was unaware of the FIF rule, and had not paid tax on the growth for two years would this be be assessed retroactively at marginal rate as well as the 15% tax on the whole growth in the superannuation fund? i.e potentially both 15% in the fund plus 45% personal income tax assessed at the time of transfer?
Originally posted by Paddy: Before we can help you need to tell us what type of super or pension scheme you are seeking to transfer from.
Sorry; here goes.
The plan is a Canadian Registered Retirement Savings Plan (RRSP). It was originally a company sponsored pension fund, but on leaving the company the pension had to be converted to an RRSP. There are two componenets; one that can be transferred to another fund or taken as an annuity, and one that is 'locked-in' under Alberta law and can only be taken as an annuity.
Revenue Canada will deduct 15% non-refundable withholding tax at source.