SuperWrap features and benefits. SuperWrap tax and administration benefits to clients

Transcription

1 SuperWrap features and benefits SuperWrap tax and administration benefits to clients

2 Contents Tax deductible expenses and excess deductions 3 Tax benefits and capital losses 6 Moving from Super to Pension 7 Higher payments to beneficiaries on death 9 Other benefits of Superwrap 10 Year end SuperWrap tax deductions 11

3 SuperWrap helps your clients build and protect their retirement nest egg offering all the choice, flexibility and control they should expect from a market leading platform. SuperWrap refers to the SuperWrap Personal Super Plan and SuperWrap Pension Plan. SuperWrap is part of the Retirement Wrap superannuation fund ('The Fund'). The underlying structure of SuperWrap allows us to offer members many of the Self Managed Super Fund (SMSF) features they are after without the administrative burden. SuperWrap takes care of all of the ongoing compliance, trustee and administration responsibilities; allowing your clients to focus on more important things such as their investment strategy. In addition, the way tax is calculated and administered on SuperWrap allows your clients to receive the maximum benefit of tax offsets and deductions available to them. This document outlines some of the tax and administration benefits of SuperWrap. This document is general in nature only, based on current tax laws and our interpretation. It does not constitute tax advice and your client s individual situation may differ. 1

4 Individualised tax treatment As SuperWrap tax calculations are performed for each individual account within SuperWrap, your client benefits from tax deductions and offsets that arise from the activity they undertake, within their own account. Annual tax information, including how tax has been calculated, is displayed online for each account. This ensures full transparency of entitlements such as franking credits and deductions. Capital Gains Tax (CGT) Parcel Selection SuperWrap allows members or advisers to select their own CGT parcel selection methodology. The default is 'minimum gain' for the Personal Super Plan. The parcel selection methodology must be made before the time of the sale. This allows members to influence the amount of capital gains realised within their account in a particular year. Individualised tax treatment Retirement Wrap Fund tax return Income $6,000 Deductions -$5,000 Capital gains $1,000 Capital losses -$1,000 Assessable income $1,000 Tax payable (@ 15%) 1 $150 Member account One 2 Member account Two 2 Member account Three 2 Member account Four 2 Income $5,000 Income $1,000 Income $0 Income $0 Deductions -$1,000 Deductions -$4,000 Capital gains $1,000 Capital losses $1,000 Assessable income $4,000 Tax payable (@15%) 1 $600 Assessable income $0 Excess deductions $3,000 Credit for excess deductions 3 $450 Assessable income $1,000 Tax payable (@15%) 1 $150 Assessable income $0 Excess capital losses $1,000 Credit for excess losses 4 $ The nominal tax rate will be 15% for accumulation members. The effective tax rate may be lower. 2. Individual member account contribution to overall Fund tax return. 3. The actual credit will depend on the rate of tax the Fund pays. 4. The actual rate of compensation provided to a client will be between 10% and 15% depending on the type of capital gains offset by the capital losses at a fund level. Please Note: Compensation will only be provided where the clients excess capital losses can be used in the overall Fund tax return. In the event that the fund is unable to use a clients excess capital losses, the members losses will stay recorded against their account until they can be utilised by their account or at a Fund level in the future. 2

5 Tax deductible expenses and excess deductions Access to deductible expenses to reduce tax payable Any tax deductible expenses incurred by your client will directly reduce their account s tax liability. A range of expenses that are tax deductible include: > > account keeping fees > > ongoing adviser fees > > regular contribution fees > > insurance premiums > > trustee fees. See Case Study 1 for an example of how one of these deductible expenses (ie insurance premiums) is treated by the SuperWrap Fund (the Fund). Tax deductibility of insurance premiums All super funds are entitled to a deduction for certain insurance premiums. Within SuperWrap, the tax advantage of this deduction is passed back directly to the client s account. While the below is a simple example, it highlights the basic methodology underpinning how SuperWrap offsets deductible expenses against Retirement Wrap income and passes the benefit of the deductions back to individual client accounts. This methodology applies to all deductible expenses in SuperWrap, which can be offset against all forms of Retirement Wrap income. Case study 1 Jack holds death and disability insurance within his SuperWrap Personal Super Plan account and incurs an annual premium of $3,000. If we assume that Jack made a taxable contribution of $3,000 in the same financial year, ignoring all other variables, the insurance premium will affect his tax payable as follows: Calculation of tax $ within Jack s account Amount of taxable contribution $3,000 included as taxable income in Jack s account Deduction credited to Jack s -$3,000 account for insurance premium Net taxable income of Jack s $0 account Tax payable $0 Note: If Jack s account did not have sufficient taxable income to fully utilise the tax deduction for the insurance premium, the deduction would, where possible, be used by the Fund, and Jack would receive the benefit back as a tax credit (see Treatment of excess deductions below for details). Note: Case Study 1 assumes that Jack s insurance premium is 100% deductible. Please note that not all insurance premiums are fully deductible. 3

6 Treatment of excess deductions Where a tax calculation performed for a client s account results in excess deductions (for example, where your client has more deductions than taxable income against which to offset the deductions), the Fund will attempt to use these excess entitlements to reduce the Fund s total tax liability. When this occurs, the Fund will pass the benefit it receives back to the client as either a reduction in their individual tax liability or as a tax credit. In effect, this means that the client benefits from excess deductions that would otherwise have resulted in a tax loss if the activity within their own account had been treated in isolation. Where a client s excess deductions are used at a fund level, the total tax payable by the Fund is reduced. Treatment of excess deductions Excess deduction in account 1 Excess deduction in account 2 Account 1 receives tax credit Account 2 receives tax credit Fund uses excess entitlements to reduce fund s total tax liability Fund passes the benefit it receives back to client s account Administrator prepares Fund level tax return Franking credits are applied directly to the member s account Investing in shares can result in certain tax advantages flowing through to the owner, where the assets are held either directly or indirectly (eg through a managed fund investment). Case study 2 looks at how franking credits from direct share ownership flow through to a client s SuperWrap account. Case study 2 Jill s account invests in direct shares, and the franking credits that are generated from those shares will pass directly to her SuperWrap Personal Super Plan account. If we assume that Jill s account received $30,000 of dividend income, which had $6,000 in franking credits attached to it, ignoring all other variables, the franking credits will affect her tax payable as follows: Calculation of tax within Jill's account $ Dividends received in Jill s account $30,000 Franking credits attached to those $6,000 dividends Amount included as taxable income $36,000 in Jill s account Tax at 15% 1 $5,400 Less tax offset for franking credit ($6,000) 1. The actual rate of tax may be lower. 4

7 When are the tax benefits of capital losses received? Ensuring the tax benefits of capital losses are received earlier SuperWrap members who have sold assets and crystallised capital losses will have these losses applied against the capital gains that have arisen within their account. The application of these losses will directly reduce the Capital Gains Tax (CGT) payable in their account. Maximising the tax benefit of capital losses 1. Client account sells an asset crystallising a capital loss 2. Client account applies capital losses against any capital gains 4. Client account receives a reduction in its tax liability or a tax credit from the Fund for any losses applied by the Fund 3. Client account s excess capital losses are applied against capital gains derived by the Fund Where a client doesn t have sufficient capital gains available to offset these losses, SuperWrap will attempt to apply the client s excess capital losses against other capital gains derived by the Fund. Where a client s excess capital losses can be offset against capital gains at the Fund level, the client will receive the benefit. The benefit will be in the form of either a reduction in their tax liability or a tax credit, depending on the tax liability of their account. This means that your client gets a benefit from the capital loss earlier than would otherwise be possible (eg: in a SMSF), as they do not have to wait for a time in the future when capital gains arise within their own account against which to offset the losses. See Case Study 3 on the next page for an example of how an individual s excess capital losses can be used at the Fund level. Where a client s excess capital losses are applied at a Fund level, the total tax payable by the Fund is reduced. The benefit of reducing the tax payable by the Fund in a given financial year is that it reduces the Fund s PAYG instalment rate. This will indirectly benefit all clients, as the rate at which tax is deducted throughout the next financial year is lower. Note that the benefit obtained from the excess deductions has a similar impact. 5

8 Tax benefits and capital losses Member credit for offsetting capital gains at a Fund level The actual rate of compensation provided to the client will be between 10% and 15% depending on the type of capital gains offset by the capital losses at a Fund level. The benefit will be: > > 15% if Retirement Wrap has only nondiscounted gains > > 15% if Retirement Wrap has only indexed capital gains > > 10% if Retirement Wrap has only discounted capital gains and > > between 10% and 15% if Retirement Wrap has a mixture of all three types of capital gains. Where SuperWrap offsets a member s capital losses against capital gains at either the individual account level or the Fund level, it will apply those losses against the Fund s capital gains, generally in the following order: 1. non-discounted capital gains 2. indexed capital gains 3. discounted capital gains. This treatment ensures that the value of your client s capital losses is maximised by offsetting them against the highest taxing capital gains first. What happens if the capital loss cannot be used at a Fund level? If a capital loss within your client s account could not be used in a given financial year it will be carried forward. In future years, carried forward losses will firstly be applied against any future capital gains that arise within your client s account, and then, where possible, at the Fund level. This process continues until all the losses are used or you close your account. Case study 3 In the 2015/16 financial year, Charlie s SuperWrap account crystallised a capital loss of $20,000 but realised no capital gains. While Charlie is unable to utilise the tax advantages of the $20,000 capital loss in 2015/16, let us assume that half of the losses in Charlie s account can be utilised at the Fund level. Let s also assume that the Fund has $10,000 of capital gains. Retirement Wrap $ Capital gains at a Fund level $10,000 Tax payable before utilising the -$1,500 capital loss in Charlie s account Using member losses at the Fund level how does it work $ in SuperWrap? Tax savings to the Fund by utilising +$1,500 the capital losses from Charlie s account ($10,000 x 15%) 1 Credit from the Fund to Charlie s -$1,500 account for the $10,000 capital loss utilised by Retirement Wrap Net change at a Fund level $0 $1,500 Charlie s account $ Income $50,000 Capital losses $20,000 Tax payable ($50,000 x 15%) 2 -$7,500 Credit from Retirement Wrap for the $10,000 loss utilised by the Fund 1 Net Tax payable in 15/16 from $6,000 Charlie s account Capital loss carried forward to 2016/17 3 $10, The actual rate of compensation provided to the client will be between 10% and 15% depending on the type of capital gains offset by the capital losses at a Fund level. 2. The actual rate of tax may be lower. 3. Any loss that is carried forward will be firstly applied against any future capital gains in Charlie s account, and then, where possible, at a Fund level. 6

9 Moving from Super to Pension Avoid unnecessary tax and fees when moving from accumulation to pension This benefit is often thought of as an advantage only available to a self managed super fund; however SuperWrap offers this same feature. By investing in SuperWrap, your clients: > > Don t incur unnecessary tax when transferring from super to pension as they do not need to realise any capital gains in the taxed accumulation phase as a result of transferring to the pension phase. Furthermore, if your client decides to change investment strategy once in the pension phase resulting in the sale of investments, no CGT will be payable, meaning that your client s pension assets are not eroded unnecessarily. > > Save on transaction and transfer costs as there are no buy/sell costs in the seamless transfer from the accumulation to the pension phase. Access a transition to retirement strategy without realising capital gains When utilising a transition to retirement strategy people often seek to consolidate their accumulation and pension accounts together on a regular basis to improve the long term outcome under the strategy. SuperWrap can help your client to consolidate their accumulated superannuation and transition to retirement pension. This can be done without selling the underlying assets, or incurring any buy/sell costs or CGT. Please note that the Government has announced its intention to remove the tax free status of transition to retirement (TTR) income streams from 1 July 2017 under its proposed 2016 Budget superannuation measures. If this measure is passed by the Parliament as proposed, any sell-down of assets within a TTR pension will be assessed for CGT and taxed accordingly. 7

10 Case study 4 Howard s superannuation fund (Fund A) purchased a portfolio of shares for $350,000 and has held them for three years. The shares are currently worth $500,000. If Howard was in the SuperWrap Personal Super Plan, his assets would be transferred seamlessly across from accumulation to pension without incurring any CGT or buy/sell costs. However, if he transferred his accumulation benefit from SuperWrap to a pension account in Fund A, CGT and buy/sell costs would be payable. This would make the following difference to the starting value of Howard s pension account: SuperWrap $ Value before transfer $500,000 Less CGT $0 Less buy/sell costs $0 Commencement value of the $500,000 SuperWrap pension Transfer from SuperWrap $ to Fund A Value before transfer $500,000 Less CGT (10% x $150,000) 1 $15,000 Less buy/sell costs $500 Commencement value of the $484,500 pension On transferring to the pension phase within SuperWrap, there is no need to sell down and re-acquire the current share portfolio. Therefore no CGT liability would arise as a result of the transfer, providing a saving of up to $15,000 in tax as well as savings in buy/sell costs. What would happen if Howard changed his investment strategy after commencing a pension in SuperWrap? 18 months after commencing a pension in SuperWrap, Howard decides to change his investment strategy and disposes of his entire share portfolio (now worth $600,000) in order to acquire different investments. In doing so, Howard s account would not incur a CGT liability as the realised capital gains are exempt from tax in the pension phase. The outcome for Howard is that his account will not be subject to any tax on the capital growth of $250,000 on his initial $350,000 investment as a result of remaining in SuperWrap from the accumulation through to the pension phase. 1. The rate of tax is based on the assumption that the shares have been held for more than 12 months. 8

11 Higher payments to beneficiaries on death Higher payments to beneficiaries on death Through SuperWrap there is the ability to calculate and pass on the anti-detriment increase in lump sum death benefit payments to eligible dependent beneficiaries upon the death of a member. This service is not offered by all funds and is especially difficult to obtain through SMSFs. Essentially the anti-detriment payment is intended to notionally compensate the member s eligible dependants for the effect of tax on contributions over the life of the member s superannuation. A trustee can only make an anti-detriment payment where a lump sum death benefit is paid to the: > > member s spouse 1, ex-spouse 1 or child 2, including an adult child 2, but not including beneficiaries who are financial dependants or in an interdependency relationship with the member at the time of death or > > deceased estate, to the extent that a spouse 1, ex-spouse 1 or child 2 is reasonably expected to benefit from the estate. Please note that the Governement has announced its intention to abolish anti-detriment payments under its proposed 2016 superannuation Budget measures. If this measure is passed, it will cease to be available from 1 July An anti-detriment payment cannot apply to death benefits paid as pensions. From 1 July 2014, beneficiaries are no longer required to submit to the Trustee a request for the anti-detriment amount to be calculated and paid, as this process will occur automatically. Formula for calculating an anti-detriment payment Superannuation funds will generally calculate the anti-detriment payment using the following formula provided in ATO ID 2007/219: (0.15 x P) x C (R 0.15 x P) where: R = the total number of days in the service period that occur after 30 June P = the number of days in component R that occur after 30 June C = the taxable component of the lump sum, after excluding the insured amount of the benefit (if there is any). Case study 5 Joe is 55 and has $300,000 in SuperWrap. He is married to Sarah, and they have two children, Amy 15, and Joshua 13. Joe s SuperWrap account contains the following $ Earliest start date 2nd January 1980 Account balance $300,000 Non-taxable component $10,000 of account Let s assume that Joe died on 3rd January 2016 and he had a valid non-lapsing nomination in place specifying that his death benefit was to be paid to Sarah. The anti-detriment payment that Sarah would be eligible to receive would be calculated in the following manner: (0.15 x 9,318) x 290,000 = $41,584 (11, x 9,318) This means that Sarah would receive a total death benefit of $341,584 ($300,000 + $41,584). As Joe s wife, she would receive this completely tax free. 1. References to spouse include defacto and same sex spouses. 2. References to child include a child of a same sex relationship. 9

12 Other benefits of Superwrap Benefits of SMSFs without the admin burden A trustee of a superannuation fund has a large range of roles and responsibilities. SuperWrap undertakes all of the following on behalf of clients: Client responsibilities comparison Client s trustee responsibilities in a SMSF fund Compliance with super legislation Compliance with Corporations Act Document and administer actions of fund Act in accordance with trust deed Review and update trust deed Make investment choices with their adviser Compliance with tax legislation Ensuring annual audit occurs Preparation and lodgement of annual return with regulator Develop and implement investment strategy Client s responsibilities in SuperWrap versus Make investment choices with their adviser As the above illustrates, SuperWrap undertakes the compliance and administration burden for the clients. If a trustee fails to adhere to the applicable rules, their superannuation fund can lose its status as a complying fund, and individual trustees could face fines and/or jail time, depending on the offence. Should a SMSF lose its complying fund status, it will no longer qualify for the generous tax concessions applied to complying superannuation funds. The fund will be subject to tax on all income and capital gains at the highest marginal rate (currently 47%) 1. Additionally, in the year the fund loses its complying status, the sum of the market value of the fund s assets immediately before the start of the year, less certain after tax contributions, will be included as income of the fund. Case study 6 Rory s SMSF became non-complying in the 2015/16 financial year. The value of the assets in the fund as at 30 June 2015 total $500,000, and investment earnings for 2015/16 were $100,000. No after tax contributions have been made to the fund. This means that for the 2015/16 financial year, Rory s fund will need to pay $282,000 in tax. Calculation of tax payable $ Fund Value (30 June 2015) $500, /16 Earnings $100,000 Total $600,000 Tax at 47% 1 $282,000 (on $500,000 + $100,000) Balance after tax $318,000 SMSFs and non residents If a client is residing or working overseas for a period of time, complications can arise which may cause their SMSF to lose its complying status. Generally, SMSFs cannot be established or maintained by non-resident trustees and they cannot accept contributions from non-residents, unless: > > the contribution relates to a period when the member was a resident, or > > the accumulated entitlements of resident active members are 50% or more of the total accumulated entitlements of all active members. SuperWrap is not impacted by the above because it has an Australian corporate trustee (BT Funds Management Limited, the Trustee) and because of the number of resident members who actively contribute to the Fund. SuperWrap members are therefore able to work overseas knowing that their superannuation fund in Australia can continue to accept contributions and remains a complying fund under superannuation law. 1. Excludes the Temporary Budget Repair Levy. 10

13 Year end SuperWrap tax deductions Note: Recent government changes mean that superannuation benefits may be more difficult to access and less tax effective for individuals who are or were temporary residents of Australia 1. Members can transfer foreign super entitlements to SuperWrap SuperWrap is able to accept transfers of overseas retirement benefits other than amounts from Kiwisaver accounts. SuperWrap is also currently unable to accept any amounts derived from a UK registered pension scheme unless Her Majesty's Revenue and Customs (HMRC) confirms that we are a Recognised Overseas Pension Scheme (ROPS) or we are otherwise eligible to receive such amounts. This includes rollovers (electronic or other) from other Australian superannuation funds that include amounts derived from a UK registered pension scheme before or after 6 April To assist your clients with transferring their overseas entitlements to SuperWrap all you need to do is: > > contact the overseas scheme provider to ensure the benefit can be transferred and confirm their requirements. > > follow the steps outlined in the Making Foreign Super Transfers Easy flyer available on the DeskTop under Resources» Flyers and Fact sheets. When is tax deducted from the member s account? In the SuperWrap Personal Super Plan, tax on employer contributions and earnings are deducted quarterly from member s accounts, in arrears, and is calculated using the current SuperWrap PAYG instalment rate (this rate is reviewed quarterly and is available on the DeskTop under Products & Research» Wrap News in Brief). The Trustee lodges the Fund s annual tax return in the financial year following the relevant income tax year. As part of this process, a calculation is performed for the Fund as a whole and any final tax adjustments for the year are made. If the amount of tax deducted from a member s account throughout the financial year is higher than required, a tax credit is paid directly to their account. Conversely, if an insufficient amount of tax has been deducted during the year to meet the member s individual tax liability, an additional amount will be deducted from the member s account. How and when the deduction of tax occurs within SuperWrap End of previous financial year End of relevant income tax year PAYG deducted (within 21 days after the quarter end) End of following financial year In the following financial year the Trustee submits a tax return to the ATO for the fund. This enables final tax adjustments to be made at an individual account level for the previous financial year. June September December March June September December March June 1. These changes do not affect: permanent residents of Australia or Australian citizens or 11 New Zealand citizens or current or former temporary residents who are or were holders of retirement visas (sub classes 405 and 410).

14 The Trustee deducts tax on employer contributions and earnings at the prevailing PAYG rate. Note: Exiting members who fully redeem will have a final tax calculation performed using information available at the time of redemption, taking into account tax offsets, tax deductions and PAYG instalments already deducted from the client s account during the financial year. A tax adjustment will then be made to the member s account prior to payment or rollover out of the SuperWrap Plan. The table below provides a broad summary of the amounts deducted from member s accounts to pay tax on contributions and earnings in SuperWrap. Tax Deductions from SuperWrap Contribution type Employer contributions Personal contributions for which a tax deduction is claimed Timing of amounts deducted from member accounts for tax on contributions and earnings Contributions tax is deducted quarterly in arrears via the PAYG instalment process Contributions tax is deducted on receipt of a personal tax deduction notice (at a rate of 15%) SG vouchers Contributions tax is deducted on receipt (at a rate of 15%) Untaxed taxable component Contributions tax is deducted on receipt (at a rate of 15%) of rollovers received Investment earnings Earnings tax is deducted quarterly in arrears via the PAYG instalment process (eg distributions and dividends) Do you have existing clients with a SMSF who wish to move to SuperWrap? If you have existing SMSF clients who wish to move to SuperWrap then it may be possible to transfer the listed securities and managed fund investments across by rolling over these assets in-specie. Please note that before transferring assets you should consider the CGT consequences and confirm that the assets are approved on the SuperWrap platform. By transferring these assets in-specie rather than selling and repurchasing the same assets, brokerage fees may be saved. We note that other non-tax factors may also need to be considered when recommending in-specie transfers to clients. Do you have clients who prefer a SMSF? If you have clients who prefer the added control of setting up their own SMSF, Investment Wrap can facilitate SMSFs and offers: > > Access to all ASX listed securities, and a selection of over 800 wholesale managed funds. > > Custodial Holdings, which means the Administrator becomes the legal owner (the client still remains the beneficial owner) and therefore will manage all share registry paperwork, only passing on those items which require participation by clients. > > Efficient participation in corporate actions via the online corporate actions calendar. > > Dividends and distributions credited directly to your client s working cash account. > > Download information for efficient tax and regulatory return preparation. Closed accounts If you close your account, SuperWrap will perform a final tax calculation on your account. This includes deduction of any prior year taxes owing and an estimate of the tax payable on any income and capital gains received in the current year. At the time of exit, SuperWrap will apply any capital losses against capital gains within your account to the extent possible and the member will receive compensation for any losses used. Any unused capital losses remain in the Fund and exited members will not receive any further compensation for the use of these losses after exiting. If the member transfers to Super Wrap Pension Plan, they may receive future compensation for the unused losses if the Fund is able to utilise the losses in the future against the Fund's total capital gains. Note: Information on how tax is calculated for specific SuperWrap members is available on the DeskTop at My Clients» estatements» Tax & Annual Statement. 12

15 For more information bt.com.au Speak to your Business Development Manager Information is current as at 4 August The taxation position described is a general statement and is for guidance only. It has not been prepared by a registered tax agent. It does not constitute tax advice and is based on current tax laws and our interpretation. Your clients individual situation may differ and they should seek independent professional tax advice. BT Portfolio Services Ltd ABN (BTPS) administers SuperWrap. BT Funds Management Limited ABN (BTFM) RSE L is the trustee and issuer of SuperWrap ABN , RSE R A Product Disclosure Statement (PDS) is available for SuperWrap. Your clients should obtain from you and consider the PDS before deciding whether to acquire, continue to hold or dispose of interests in SuperWrap. Your Dealer Group may also operate a Wrap offering, otherwise its role in relation to Wrap and SuperWrap (Wrap Products) is limited to distributor only. This information has been prepared without taking account of any individual s objectives, financial situation or needs. Because of this your clients should, before acting on this information, consider its appropriateness having regard to their objectives, financial situation or needs. BTPS s financial services guide can be obtained by calling Wrap Adviser Relations on or visiting the Wrap DeskTop. Superannuation is a long-term investment. The government has placed restrictions on when investors can access preserved benefits. The Government has set caps on the amount of money that can be added to superannuation each year on a concessionally taxed basis. In addition, the government has set a non-concessional contributions cap. For more detail clients should speak to you, their financial adviser, or visit the ATO website. BTPS and BTFM are subsidiaries of Westpac Banking Corporation ABN (Westpac). Apart from any interest investors may have in underlying bank accounts held at Westpac through a SuperWrap Cash Account or Westpac securities acquired through SuperWrap, an investment in, or acquired using, SuperWrap is not an investment in, deposit with or any other liability of Westpac or any other company in the Westpac Group. These investments are subject to investment risk, including possible delays in repayment of withdrawal proceeds and loss of income and principal invested. Westpac and its related entities do not stand behind or otherwise guarantee the capital value or investment performance of any investments in, or acquired through, SuperWrap. This document has been prepared and is provided solely for the general guidance of advisers. It may not be copied, used, reproduced or otherwise distributed or circulated without the prior written consent of BT Portfolio Services Ltd. BT Portfolio Services BT9931C-0816lc