This chapter contains information on the accumulation phase [2] of superannuation, including outlines of the various types of superannuation structures.
It also covers the assessment of income from withdrawals of superannuation benefits.
See Also
Superannuation
Chapter 9.1 Income and Assets Test Principles [3]
Chapter 9.5 Deeming Provisions [4]
The accumulation phase is the period during a person's working life in which superannuation contributions are paid into a superannuation fund, with the aim of maximising the sum available for retirement through investment and tax concessions.
The primary purpose of a superannuation scheme is to provide its beneficiaries with financial resources and other benefits during their retirement.
More → [9]
To provide eventual retirement benefits, both employer-sponsored and personal superannuation schemes:
The two main types of superannuation funds are:
An eligible termination payment [2] is a lump sum payment, made by an employer or a superannuation fund when a person leaves employment, by:
Roll-over [2] funds are approved investment funds for eligible termination payments, some of which must be preserved.
Preserved amounts generally cannot be accessed until the beneficiary:
The superannuation legislation allows early release of preserved superannuation benefits [2] in limited circumstances. Circumstances include severe financial hardship, specified grounds such as medical treatment or permanent incapacity, and in special circumstances where a person has permanently departed Australia.
More → [11]
The following factors govern the assessment of a pensioner's superannuation assets by DVA [2]
Prior to 1 July 2013, the compulsory superannuation guarantee contributions paid by employers are limited to employees under 70 years of age, and are paid at a minimum of 9% of the employee's ordinary time earnings. This applies whether the person is in full time, part time or casual employment. Employers are required to pay these amounts into a complying superannuation fund [2].
From 1 July 2013, the compulsory superannuation guarantee contributions will be extended to people aged 70 years and over. It is intended that the 9% rate will progressively increase by variable annual increments, reaching 12% in 2019-20.
For a person who has attained pension age [2], the superannuation fund money (including the compulsory employer contributions) may be held in accumulation mode, with the current value being assessed as a financial asset and deemed. At the time of converting the superannuation fund money to pension, the income stream rules apply.
It is not necessary for pensioners to notify the Department of their compulsory superannuation guarantee contributions, as they are not assessed as income [2]. Increases in the value of the superannuation fund investment held in accumulation mode are reportable.
Pensioners also need to notify the commencement of a pension payment by providing an income stream schedule [13]. The income support assessment depends on the commencement date of the income stream and whether the owner has continuously received an income support payment since 31 December 2014. The income stream will be assessed by either:
Early release of superannuation benefits - hardship
10.4.3/Early Release of Superannuation Benefits [21]
Chapter 3.10 Financial Hardship [22]
The accumulation phase is the period during a person's working life in which superannuation contributions are paid into a superannuation fund, with the aim of maximising the sum available for retirement through investment and tax concessions.
A superannuation fund is defined in the VEA as being:
The draw down phase is the period, after retirement from the workforce, when a person receives regular payments of superannuation benefits from their superannuation fund or an income stream product.
An employee is someone who is:
An ETP is a payment (usually on retirement or termination of employment) which receives concessional tax treatment according to a specified set of rules. It can be transferred to funds which have been granted similar tax concessions by the government.
To roll-over, in relation to an eligible termination payment, means to invest all or part of the payment in an approved superannuation or roll-over fund, according to the requirements of section 27D of the Income Tax Assessment Act, 1936.
Preservation age is the age at which a person may be able to gain access to preserved benefits held in approved deposit funds and superannuation.
From 2015 to 2025, the preservation age will gradually increase to sixty years for people born after 1 July 1960. Specifically:
For a person born... | preservation age is... |
before 1 July 1960 | 55 years old |
during the year 1 July 1960 to 30 June 1961 | 56 years old |
during the year 1 July 1961 to 30 June 1962 | 57 years old |
during the year 1 July 1962 to 30 June 1963 | 58 years old |
during the year 1 July 1963 to 30 June 1964 | 59 years old |
after 30 June 1964 | 60 years old. |
To access preserved benefits on reaching preservation age, an income support recipient must also satisfy one of the following:
The person must also meet the conditions of the particular fund's governing rules.
Legislative reference: Regulation 6.01 Supernnuation Industry (Supervision) Regulations 1994
Section 5J(1) of the VEA [28] defines a superannuation benefit, in relation to a person, as a benefit arising directly or indirectly from amounts contributed (whether by the person or by any other person) to a superannuation fund in respect of the person.
The Department of Veterans' Affairs.
A superannuation fund is defined in the VEA as being:
Currently, the pension age for a veteran is 60 years of age (VEA 5QA).
The pension age for a non-veteran is determined by the table below:
Date of birth (both dates inclusive) | Age Pension age |
1 July 1952 to 31 December 1953 | 65 years and 6 months |
1 January 1954 to 30 June 1955 | 66 years |
1 July 1955 to 31 December 1956 | 66 years and 6 months |
On or after 1 January 1957 | 67 years |
According to section 5H of the VEA [29] income is:
This section contains the general provisions on superannuation and describes its structure.
It also contains information about the types of superannuation schemes, eligible termination payments [2] and roll-over [2] funds.
An ETP is a payment (usually on retirement or termination of employment) which receives concessional tax treatment according to a specified set of rules. It can be transferred to funds which have been granted similar tax concessions by the government.
To roll-over, in relation to an eligible termination payment, means to invest all or part of the payment in an approved superannuation or roll-over fund, according to the requirements of section 27D of the Income Tax Assessment Act, 1936.
The primary purpose of a superannuation scheme is to provide its beneficiaries with financial resources and other benefits during their retirement. Other benefits in some schemes include death benefits for surviving dependants and disability benefits. The Australian superannuation system is intended to fund higher standards of retirement living than continuing reliance on income support pensions [2] as the primary source of retirement income. Most Australians in the workforce are now covered by superannuation schemes with membership and contributions that are either:
To provide eventual retirement benefits, both employer-sponsored and personal superannuation schemes:
The fund's trustee is responsible for implementing an appropriate investment strategy to protect the interests of beneficiaries while increasing the value of the fund's assets.
Depending on the type of fund, benefits paid on retirement or earlier departure from the fund consist of:
Income support pension is:
The superannuation law includes:
An employee is someone who is:
The accumulation phase is the period during a person's working life in which superannuation contributions are paid into a superannuation fund, with the aim of maximising the sum available for retirement through investment and tax concessions.
The draw down phase is the period, after retirement from the workforce, when a person receives regular payments of superannuation benefits from their superannuation fund or an income stream product.
The following table shows the differences in treatment of contributions and benefits between the two main types of superannuation funds [2].
Fund type |
Contributions |
Benefits |
Accumulation or defined contribution |
Defined for employers and employees [2] such as a percentage of salary |
Lump sum - Amount depends on performance of fund and amount of contributions. |
Defined benefit |
Employee's contributions defined. Employers contribute whatever additional amounts are needed to meet fund's obligations to its beneficiaries. |
Either:
Amount is usually based on final salary or average final salary (often the last 3 years) x a multiple. The multiple itself is usually a combination of length of membership and a percentage of final salary for each year of service. |
The various types of employer sponsored and personal superannuation schemes include:
Description of Self Managed Superannuation Funds and Small APRA Funds
10.5.5/Description of Self Managed Superannuation Funds and Small APRA Funds [34]
More ? (go back) [35]
A superannuation fund is defined in the VEA as being:
An employee is someone who is:
This is a fund with less than five members that does not meet the criteria for an SMSF. The trustee of an SAF must be a corporate trustee approved by APRA. The trustee may receive remuneration for acting as trustee.
An ATO small superannuation account is an account kept in the name of an individual under the Small Superannuation Accounts Act 1995.
This section contains information on the income [2] and assets [2] testing, in the accumulation phase [2], of income from withdrawals of superannuation benefits [2].
According to section 5H of the VEA [29] income is:
An asset means any property, including property outside Australia.
The accumulation phase is the period during a person's working life in which superannuation contributions are paid into a superannuation fund, with the aim of maximising the sum available for retirement through investment and tax concessions.
Section 5J(1) of the VEA [28] defines a superannuation benefit, in relation to a person, as a benefit arising directly or indirectly from amounts contributed (whether by the person or by any other person) to a superannuation fund in respect of the person.
DVA's assessment of a pensioner's superannuation assets depends on:
VEA → [38]
No income or asset value is assessed from superannuation in the accumulation phase where the person is below pension age [2]. If the person has reached pension age, the superannuation is assessed under the income and assets tests as a financial asset [2].
More → [43]
VEA → [44]
Superannuation in the accumulation phase may be exempted from the assets test in certain limited circumstances. Delegation to exempt superannuation in these circumstances is held by the National Manager, Rehabilitation and Entitlements Policy Group. Exemptions are only allowed where the person cannot access their superannuation due to:
VEA → [47]
Part IIIB, Division 4 [48] VEA – Income from income streams
Part IIIB, Division 11, Subdivision A [49] VEA – Value of person's assets
The income and asset value of superannuation in the drawdown phase is assessed according to the income stream [2] rules. This also applies if the superannuation is in the drawdown phase and the person is below pension age.
More → [51]
Whole of life superannuation policies are subject to the same rules as other superannuation funds. However, whole of life conventional life insurance products are treated differently.
More → [52]
The assessable asset value of whole of life superannuation policies is the accumulated superannuation benefit [2] shown on the pensioner's latest statement of account. The amount payable from the policy in the event of the death of the insured party is not relevant.
A superannuation interest in the accumulation phase may be split where members of a couple separate and one or both members of the couple have a superannuation interest. The split may be made under a superannuation agreement or a court order. The options available for splitting a superannuation interest are:
Regardless of the option chosen for splitting a superannuation interest, the non-member is not entitled to receive any further payments. Different rules apply to superannuation interests in the drawdown phase.
More → [53]
The deprivation rules do not apply to the splitting of a superannuation interest pursuant to an agreement or a court order.
Part IIIB, Division 4 [48] VEA – Income from income streams
Part IIIB, Division 11, Subdivision A [49] VEA – Value of person's assets
The accumulation phase is the period during a person's working life in which superannuation contributions are paid into a superannuation fund, with the aim of maximising the sum available for retirement through investment and tax concessions.
The draw down phase is the period, after retirement from the workforce, when a person receives regular payments of superannuation benefits from their superannuation fund or an income stream product.
Currently, the pension age for a veteran is 60 years of age (VEA 5QA).
The pension age for a non-veteran is determined by the table below:
Date of birth (both dates inclusive) | Age Pension age |
1 July 1952 to 31 December 1953 | 65 years and 6 months |
1 January 1954 to 30 June 1955 | 66 years |
1 July 1955 to 31 December 1956 | 66 years and 6 months |
On or after 1 January 1957 | 67 years |
According to section 5J(1) [28] of the VEA a financial asset means;
According to subsection 5J(1) of the VEA [28], an income stream includes:
but does not include any of the following:
Section 5J(1) of the VEA [28] defines a superannuation benefit, in relation to a person, as a benefit arising directly or indirectly from amounts contributed (whether by the person or by any other person) to a superannuation fund in respect of the person.
A superannuation fund is defined in the VEA as being:
To roll-over, in relation to an eligible termination payment, means to invest all or part of the payment in an approved superannuation or roll-over fund, according to the requirements of section 27D of the Income Tax Assessment Act, 1936.
Last amended: 13 August 2013
The superannuation law [2] allows release of preserved superannuation benefit [2] when the person has reached preservation age [2] and the person either:
Early release of benefits on the grounds of severe financial hardship is permitted when:
The following table shows the conditions to be met for people who request the early release of their superannuation benefits to be classed as being in severe financial hardship. Different conditions apply where the superannuation benefit [2] is held in the Superannuation Holding Accounts Reserve [2].
If a person's age is... |
They are in severe financial hardship if they received an income support payment... |
And withdrawals are ... |
less than 55 years and 39 weeks |
for a continuous period of 26 weeks immediately prior to application. Pensioners also need to satisfy the superannuation fund trustee that they are unable to meet reasonable and immediate family living expenses |
restricted to one withdrawal and a maximum $10,000 each twelve months. |
55 years and 39 weeks or more |
People of this age who do not meet these requirements will also be able to access their superannuation if they meet the requirements for people less than 55 years and 39 weeks. |
not restricted. |
The qualifying period of income support for superannuation investments in superannuation holding accounts reserve is fifty two weeks (continuous) for people aged less than 55 years and 39 weeks, and at least thirty nine weeks (cumulative) for people aged 55 years and 39 weeks or more.
Applications for release of superannuation benefits on the grounds of severe hardship are made to the person's superannuation fund, and must be submitted with a letter confirming the period of the person's income support payments received from DVA [2]. DVA does not have any role in whether all of the conditions for early release of benefits have been met. DVA's only role is to supply, on request from a person, confirmation that the pensioner has received income support payments for the required period.
Pensioners must notify DVA if any benefits are released, as this may affect their income support payments.
More → [61]
There are very limited compassionate grounds that allow a person who does not meet the income support requirements to gain access to their superannuation benefits. These include a requirement to pay for medical treatment or medical transport, mortgage assistance, modifications to a home and/or motor vehicle in the case of a severe disability, care for a terminal medical condition, or for funeral assistance. The Department of Human Services considers applications on compassionate grounds, and a person's superannuation fund trustee or retirement savings account provider can provide advice to pensioners.
The superannuation law includes:
Section 5J(1) of the VEA [28] defines a superannuation benefit, in relation to a person, as a benefit arising directly or indirectly from amounts contributed (whether by the person or by any other person) to a superannuation fund in respect of the person.
Preservation age is the age at which a person may be able to gain access to preserved benefits held in approved deposit funds and superannuation.
From 2015 to 2025, the preservation age will gradually increase to sixty years for people born after 1 July 1960. Specifically:
For a person born... | preservation age is... |
before 1 July 1960 | 55 years old |
during the year 1 July 1960 to 30 June 1961 | 56 years old |
during the year 1 July 1961 to 30 June 1962 | 57 years old |
during the year 1 July 1962 to 30 June 1963 | 58 years old |
during the year 1 July 1963 to 30 June 1964 | 59 years old |
after 30 June 1964 | 60 years old. |
To access preserved benefits on reaching preservation age, an income support recipient must also satisfy one of the following:
The person must also meet the conditions of the particular fund's governing rules.
Legislative reference: Regulation 6.01 Supernnuation Industry (Supervision) Regulations 1994
A superannuation fund is defined in the VEA as being:
Section 5J(1) of the VEA [28] defines a superannuation benefit, in relation to a person, as a benefit arising directly or indirectly from amounts contributed (whether by the person or by any other person) to a superannuation fund in respect of the person.
The superannuation holding accounts reserve is the fund in which small accounts administered by the Australian Taxation Office are held.
The Department of Veterans' Affairs.
The income and assets test assessments of a withdrawal from superannuation assets depends on:
A withdrawal made during the drawdown phase is considered to be a commutation. Commutations are assessed under the income streams rules.
More → [65]
The assets test [2] assessment of a withdrawal from a superannuation fund [2] depends on how the amount withdrawn is used. For example, if invested in bank account it becomes a financial asset [2], if used to pay the mortgage of the principal home [2] it becomes exempt. If the person has not reached preservation age, withdrawal is allowed only on financial hardship or compassionate grounds. It is likely in these cases that there will be no impact as the amount withdrawn would likely be spent on living expenses or similar.
Withdrawals from superannuation in the accumulation phase are not assessed as income.
The accumulation phase is the period during a person's working life in which superannuation contributions are paid into a superannuation fund, with the aim of maximising the sum available for retirement through investment and tax concessions.
The draw down phase is the period, after retirement from the workforce, when a person receives regular payments of superannuation benefits from their superannuation fund or an income stream product.
One element of the means test for income support pensions whereby the rate of pension payable to a pensioner reduces progressively as their assets increase above a certain threshold known as the assets value limit (AVL). [68]
A superannuation fund is defined in the VEA as being:
According to section 5J(1) [28] of the VEA a financial asset means;
The principal home has the meaning given by subsection 5LA(1) [28] of the VEA and subsection 5LA(2) [28] of the VEA. The principal home of a person is generally the place in which they reside. In certain circumstances, however, the principal home of a person can be the place in which they formerly resided. The following property is regarded as part of the principal home.
Amounts in superannuation funds [2] owned by a non-pensioner partner [2] are exempt from assessment for the pensioner's income support pension [2] until the non-pensioner partner reaches pension age [2], regardless of whether or not the non-pensioner partner claims pension. When the non-pensioner partner reaches pension age their superannuation affects the pensioner's entitlements as follows:
If a non-pensioner partner invests any withdrawal amounts outside the superannuation environment, the investment is assessed under the usual income and assets test rules applying to that type of investment.
More ? [72]
A superannuation fund is defined in the VEA as being:
A person's 'partner' is someone who is a member of a couple with that person.
Income support pension is:
Currently, the pension age for a veteran is 60 years of age (VEA 5QA).
The pension age for a non-veteran is determined by the table below:
Date of birth (both dates inclusive) | Age Pension age |
1 July 1952 to 31 December 1953 | 65 years and 6 months |
1 January 1954 to 30 June 1955 | 66 years |
1 July 1955 to 31 December 1956 | 66 years and 6 months |
On or after 1 January 1957 | 67 years |
The accumulation phase is the period during a person's working life in which superannuation contributions are paid into a superannuation fund, with the aim of maximising the sum available for retirement through investment and tax concessions.
According to section 5J of the VEA, a financial investment means:
but does not include an investment in an FHSA (within the meaning of the First Home Saver Accounts Act 2008) or a designated NDIS amount.
According to subsection 5J(1) of the VEA [28], an income stream includes:
but does not include any of the following:
Links
[1] https://clik.dva.gov.au/user/login?destination=node/16549%23comment-form
[2] https://clik.dva.gov.au/%23
[3] https://clik.dva.gov.au/compensation-and-support-policy-library/part-9-principles-determining-pension-rate/91-income-and-assets-test-principles
[4] https://clik.dva.gov.au/compensation-and-support-policy-library/part-9-principles-determining-pension-rate/95-deeming-provisions
[5] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/101-ordinary-income
[6] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/102-assets
[7] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/105-income-streams
[8] https://clik.dva.gov.au/user/login?destination=node/16317%23comment-form
[9] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn585
[10] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn586
[11] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn587
[12] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn588
[13] http://awsp76:81/sites/default/files/dvaforms/D0563.pdf
[14] https://clik.dva.gov.au/compensation-and-support-policy-library/part-9-principles-determining-pension-rate/95-deeming-provisions/957-deemed-income-account-based-income-streams-0
[15] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/105-income-streams/1054-income-and-assets-assessment-income-streams/income-assessment-purchased-income-streams
[16] https://clik.dva.gov.au/book/export/html/16549#tgt-More_ftn1
[17] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/104-superannuation-funds/1042-description-superannuation/what-superannuation
[18] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn585
[19] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/104-superannuation-funds/1042-description-superannuation/types-superannuation-funds
[20] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn586
[21] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/104-superannuation-funds/1043-assessment-superannuation-benefits/early-release-superannuation-benefits
[22] https://clik.dva.gov.au/compensation-and-support-policy-library/part-3-income-support-eligibility/310-financial-hardship
[23] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn587
[24] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/104-superannuation-funds/1043-assessment-superannuation-benefits
[25] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn588
[26] https://clik.dva.gov.au/book/export/html/16549#ref-More_ftn1
[27] http://clik.dva.gov.au/glossary/foreign-superannuation-fund
[28] http://clik.dva.gov.au/legislation-library
[29] http://clik/health-procedure-library/health-information-and-management-notes-himn/vhc/072014-vhc-veterans-home-care
[30] https://clik.dva.gov.au/user/login?destination=node/16484%23comment-form
[31] https://clik.dva.gov.au/user/login?destination=node/16430%23comment-form
[32] https://clik.dva.gov.au/user/login?destination=node/16554%23comment-form
[33] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn589
[34] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/105-income-streams/1055-special-provisions-regarding-self-managed-superannuation-funds-and-small-apra-funds/description-self-managed-superannuation-funds-and-small-apra-funds
[35] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn589
[36] https://clik.dva.gov.au/user/login?destination=node/16506%23comment-form
[37] https://clik.dva.gov.au/user/login?destination=node/16403%23comment-form
[38] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn590
[39] clik://LEGIS/VEA/section 5H(8)
[40] clik://LEGIS/VEA/section 5J(1)
[41] clik://LEGIS/VEA/section 52(1)
[42] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn590
[43] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn591
[44] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn592
[45] clik://LEGIS/VEA/section 52AA
[46] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn592
[47] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn593
[48] clik://LEGIS/VEA/Div 4/Part IIIB
[49] clik://LEGIS/VEA/SubDiv A/Div 11/Part IIIB
[50] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn593
[51] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn594
[52] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn595
[53] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn596
[54] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn591
[55] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn594
[56] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/102-assets/1024-assessing-personal-assets-and-investments/assessing-life-insurance-policies
[57] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn595
[58] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/105-income-streams/1056-special-provisions-regarding-family-law-affected-income-streams
[59] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn596
[60] https://clik.dva.gov.au/user/login?destination=node/16358%23comment-form
[61] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn597
[62] https://clik.dva.gov.au/compensation-and-support-policy-library/part-12-compliance-and-obligations/121-recipient-obligations
[63] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn597
[64] https://clik.dva.gov.au/user/login?destination=node/16535%23comment-form
[65] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn598
[66] https://clik.dva.gov.au/compensation-and-support-policy-library/part-10-types-income-and-assets/105-income-streams/1053-general-provisions-assessing-income-streams/additional-rules-regarding-commutation
[67] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn598
[68] http://clik.dva.gov.au/glossary/assets-value-limit-avl
[69] https://clik.dva.gov.au/user/login?destination=node/16428%23comment-form
[70] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn599
[71] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn600
[72] https://clik.dva.gov.au/book/export/html/16549#tgt-cspol_part10_ftn601
[73] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn599
[74] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn600
[75] https://clik.dva.gov.au/book/export/html/16549#ref-cspol_part10_ftn601