This paper is a further developed version of the author’s submission to the Treasury consultation on the federal government’s Better Targeted Superannuation Concessions proposal, lodged in April 2023. The proposal is to add to the existing superannuation tax system a total balance threshold of $3 million, beyond which individuals would be subject to an additional tax on a portion of the earnings of their superannuation balances.

The approach of this submission is in three steps:

1. To question the fundamental justification for a new tax measure aimed at increasing superannuation tax revenue and targeting those with large balances;
2. To critique the specific design features of the proposal and to canvass improvements in the event that such a proposal proceeds; and
3. To suggest different ways to raise additional revenue from superannuation if the government remains determined to do so.