"There are always individuals who are interested in it without understanding what the potential ramifications can be," said Mr Miller.

While increasing the SMSF limit from four to six will increase the capacity for SMSFs to invest in these kinds of investments, he said, it also increases the capacity of the fund to have investment problems.

"Undertaking property development inside an SMSF has its own risks associated with it, particularly when you start to deal with leveraging and those sorts of issues," he cautioned.

"Often these transactions are better dealt with through an external entity. So rather than having all that activity within the super fund, hold it an unrelated trust and then participate on a fund by fund basis. I think that provides greater flexibility than trying to do it all within the one entity."

While undoubtedly one of the positives of having more members in the fund is greater access to capital and investments, he said, it also potentially creates greater liquidity issues if a member dies or a member leaves.

"All of a sudden you've got all these assets tied up in illiquid property investments and you have to find some other way to source those payments, so it comes with it's own administrative and investment issues as well."