“Much has been made of the measure affecting only 80,000 members,” he said.

“That no-one is mentioning the 69,000 of these who have less than $5 million is curious given that this measure is being promoted as one of equity and not a simple tax grab.

“Incidentally, almost all of the unintended negative consequences could be avoided by increasing the cap to $5m.”

Mr Busoli said the paper does tick the box that requires public consultation, but continued that after sending emails to Members of Parliament about his concern, the ones that responded said they would be relying purely on the findings of Treasury instead of other agencies.

“A cynic might suggest that, with the terms of reference provided, Treasury’s findings are already largely known – but I hope I’m wrong,” he said.

He said, however, there is a positive that has arisen in the consultation process in that due to the complicated calculations on which the policy is based, limited recourse borrowings can now be counted as an asset for total super balance purposes.

“Related party loans and loans participated in by members whose benefits are unrestricted non-preserved – are likely to be generally disregarded for the total super balance count,” he said.

“This would indeed be an equity measure as it would remove the mutually contradictory scenario whereby affected members are prevented from making non-concessional contributions to liquidate a loan so they can make the non-concessional contributions to do so.

“Its introduction, promoted as an integrity measure by Treasury, has always seemed to me to be a solution seeking a problem. Let’s hope that Treasury’s findings on the current equity measure show somewhat more insight.”

Submissions on the proposed extra tax for high balance members closed on Monday, 17 April. “Given that the cap proposed is not indexed, it will have a much larger effect than what has been indicated,” Mr Busoli said.