“It is easily avoided by a change in asset-allocation, by bringing accumulation members into the fund or by partial or full transfer into an APRA fund, so it will not deliver all the tax claimed,” the report said.

It also criticised the proposed policy as being product specific as it will attack SMSFs, but few other types of superannuation funds.

The report said the policy will also encourage retirees to shift away from Australian shares to less appropriate assets, which could weaken Australia’s domestic capital market given that SMSFs hold more than 12 per cent of listed Australian shares.

Rice Warner also questioned whether the new tax would be necessary in light of the other changes to the tax system proposed by Labor which will raise significant amounts from wealthier Australians.

“Should Labor need this additional revenue, there are better ways of collecting it,” the report said.

Another mechanism that could be considered for collecting tax from those with large imputation credit rebates, the report said, is to have a rebate threshold which would exclude most people with low credits and cap those with large ones.

The amount could be set at $3,000 to $5,000 per taxpayer, the report said.

“[Another] option would be to force members to transfer excessive amounts out of superannuation when they reach a certain age say, 65,” it suggested.

“We suggest a threshold of say $3.2 million for all accumulation and pension accounts combined. In other words, double the pension transfer balance. Amounts above this would be transferred tax-free out of the low-tax superannuation environment.”