A Limited Recourse Borrowing Arrangement lets your Self-Managed Super Fund acquire investment property using borrowed funds, with the loan held in a bare trust structure until the debt is cleared.
The mechanics differ from personal lending in several material ways. The loan sits in a custodian trust, the fund trustees are the borrowers, the deposit comes from member contributions or fund reserves, and servicing relies on a combination of rental income and future contributions. Not every lender offers SMSF lending, and those that do apply stricter LVR caps and different serviceability tests than you would see with an owner-occupier or standard investment loan. Whether that structure makes sense depends on your fund balance, your contribution capacity, and the specific property you intend to acquire.
Why the Bare Trust Structure Exists
The bare trust holds legal title to the property while your fund repays the loan. Once the loan is discharged, title transfers to the fund directly. This structure satisfies the limited recourse requirement under superannuation law, which means the lender's claim is limited to the asset held in the trust. Your other fund assets remain quarantined if the loan defaults.
The trustee of the bare trust is usually a corporate entity nominated by you, and that entity has no discretion over the property. It holds title on behalf of the fund and follows instructions from the SMSF trustee. The arrangement must comply with the sole purpose test, meaning the property must be acquired to provide retirement benefits, not to deliver personal use or benefit to members before retirement.
LVR and Deposit Requirements
Most SMSF lenders cap the loan at 80% of the property's value, though some restrict that to 70% for commercial assets or higher-risk property types. Your fund needs to contribute the deposit and cover all acquisition costs from its own reserves or from member contributions made before settlement.
Consider a fund with $400,000 in cash acquiring a residential property in Reservoir. At an LVR of 80%, the fund could borrow up to $320,000, meaning it would need to hold $80,000 for the deposit plus another $15,000 to $20,000 for stamp duty, legal fees, and other settlement costs. If the fund balance sits below that threshold, members can make concessional or non-concessional contributions to top it up, provided those contributions fall within their annual caps.
Serviceability then becomes the second filter. Lenders assess whether the rental income, combined with projected member contributions, can service the loan and leave enough buffer for fund expenses. They typically require the fund to demonstrate an exit strategy, which might involve ongoing contributions, a future sale, or a refinance once the LVR improves. You cannot rely on fund members providing personal guarantees because the loan must remain limited recourse.
Residential vs Commercial Property Structures
A residential SMSF loan applies when your fund acquires a house, unit, or apartment that will be leased to an unrelated tenant. Lenders treat these as lower risk than commercial assets because residential property generally has more liquid resale markets and shorter vacancy periods. Rates for residential SMSF lending typically sit 0.5% to 1.0% above standard investment loan rates, reflecting the added structure and compliance overhead.
A commercial SMSF loan becomes relevant when the fund buys an office, warehouse, retail premises, or industrial unit. These loans often come with lower LVR caps and higher rates because vacancy risk and tenant concentration are both elevated. One distinction that changes the structure entirely is whether the commercial property will be leased to a related party, such as a business operated by a fund member. That arrangement is permissible under superannuation law provided the lease is on arm's length terms, the rent reflects market value, and the lease is documented properly. A commercial property loan for a related-party lease requires careful structuring to meet compliance tests, but it can deliver both rental income to the fund and cost certainty to the business.
Ready to get started?
Book a chat with a SMSF Finance & Mortgage Brokers at SMSF Property Finance today.
How Rental Income is Taxed Inside the Fund
Rental income earned by the fund during accumulation phase is taxed at 15%, the same rate that applies to concessional contributions and other fund income. Deductible expenses include loan interest, property management fees, council rates, insurance, repairs, and depreciation. The fund lodges an annual tax return, and those deductions reduce the taxable income before the 15% rate is applied.
Capital gains are also concessional. If the property is sold after being held for more than 12 months, the fund receives a one-third discount on the gain, meaning the effective CGT rate becomes 10%. If a member enters pension phase and the property is sold while supporting a pension, the gain may be entirely tax-free, though that depends on timing and the fund's overall position.
Those tax settings are what make the SMSF structure attractive relative to holding property in a personal name or a company. The combination of 15% income tax and 10% effective CGT compares favourably to marginal tax rates above 37%, particularly for members in higher income brackets who intend to hold the property for the long term.
When a Related-Party Lease Applies
If your fund owns a commercial property and leases it to a business you control, the lease must satisfy arm's length requirements. That means the rent must reflect market rates, the lease must be documented, and the terms must be no more favourable than what an unrelated tenant would receive. The fund cannot lease residential property to a related party, even at market rent, because that breaches the sole purpose test.
In a scenario where a fund acquires a small warehouse in Moorabbin and leases it back to a member's manufacturing business, the rent paid by the business becomes income to the fund, taxed at 15%. The business can claim the rent as a deductible expense. The loan used to acquire the warehouse must still meet limited recourse rules, and the lease itself must be reviewed periodically to confirm the rent remains at market.
This structure works well when the business needs premises, the fund has sufficient balance to contribute the deposit, and the member wants to build a tangible retirement asset while also securing tenancy for their business. It does not work if the business cannot afford market rent or if the fund lacks the liquidity to cover holding costs during any vacancy period.
Fixed vs Variable Rate SMSF Loans
SMSF lenders offer both fixed and variable rate products, though the fixed rate terms are typically shorter than what you would see with a personal loan. Fixed terms usually range from one to five years, with variable rate loans providing more flexibility around prepayments and fund contributions.
A variable rate loan allows the fund to make additional repayments as members contribute or as rental income accumulates, which can reduce the loan term and the total interest cost. A fixed rate provides certainty around repayments during the fixed period, which helps with cash flow forecasting, but prepayment restrictions apply, and break costs can be material if the fund wants to refinance or pay down the loan early.
The choice depends on the fund's contribution strategy and the member's view on rate movements. If members plan to make lumpy contributions as bonuses or business profits are realised, a variable rate gives more flexibility. If the fund's cash flow is tight and certainty is more valuable than optionality, a shorter fixed term may be appropriate.
Borrowing Capacity and Contribution Limits
Your SMSF's borrowing capacity is not assessed the same way a personal loan would be. Lenders look at the fund's ability to service the loan using rental income and projected contributions, rather than the personal income of the trustees. If the rental income alone does not cover the loan repayments, the lender will require evidence that members can and will contribute enough to make up the shortfall.
Concessional contribution caps currently sit at $30,000 per member per year, and non-concessional caps are $120,000 per year or $360,000 over three years if bring-forward rules apply. If your fund needs $25,000 a year in contributions to service a loan, and you have two members, that requires $12,500 per member annually, which fits comfortably within the concessional cap. If the shortfall is larger, the fund may need to rely on non-concessional contributions or rental income growth over time.
Serviceability is where many applications stall. If the rental income is insufficient and the members are already maximising contributions for other purposes, the lender may decline the loan or offer a lower amount. That is why it is critical to model the cash flow before committing to a property, particularly if the fund balance is modest or the members are close to retirement.
What Happens During an SMSF Loan Application
The application process involves the fund trustees, the bare trust deed, the property valuation, and the lender's credit assessment. You will need to provide the fund's trust deed, recent financial statements, tax returns, and an actuary certificate if the fund is paying pensions. The lender will also require a property valuation, a rental appraisal, and confirmation that the acquisition complies with the sole purpose test.
The bare trust deed must be drafted before settlement, and the trust must be established with a separate trustee entity. Some lenders provide template deeds, while others require the deed to be prepared by a solicitor familiar with SMSF structures. Settlement then proceeds with the property acquired in the name of the bare trustee, and the loan funds advanced to complete the purchase.
Once the property is acquired, the fund is responsible for all ongoing costs, including loan repayments, property management, and compliance reporting. If the fund refinances the loan or pays it out early, title transfers from the bare trustee to the SMSF trustee, and the trust is wound up.
Refinancing an Existing SMSF Loan
If your fund already holds a property with a loan attached, refinancing can reduce the rate, improve the loan structure, or release equity if the property has increased in value and the LVR has dropped. Refinancing follows a similar application process to the original loan, with the added step of discharging the existing lender and transferring the mortgage.
Refinancing makes sense when rates have moved materially, when the original lender no longer suits the fund's needs, or when the fund wants to consolidate multiple loans into a single facility. It does not make sense if the cost of exiting the current loan, including break costs and legal fees, exceeds the benefit of the new rate.
Call one of our team or book an appointment at a time that works for you if you are considering whether your fund structure and balance can support an SMSF property loan, or if you need clarity on how LVR, serviceability, and contribution limits apply to your specific situation.
Frequently Asked Questions
What deposit does an SMSF need to buy investment property?
Most lenders require your fund to contribute at least 20% of the property value as a deposit, plus all acquisition costs including stamp duty and legal fees. The deposit must come from fund reserves or member contributions, not from borrowed funds.
Can my SMSF lease a commercial property to my own business?
Yes, provided the lease is on arm's length terms, the rent reflects market value, and the arrangement is documented properly. Residential property cannot be leased to a related party under any circumstances.
How is rental income from an SMSF property taxed?
Rental income is taxed at 15% during accumulation phase, with deductions available for loan interest, management fees, and other property expenses. If the fund is in pension phase, the income may be tax-free.
What is a bare trust in an SMSF property loan?
A bare trust holds legal title to the property while your fund repays the loan. Once the loan is discharged, title transfers to the SMSF. This structure ensures the loan remains limited recourse, protecting other fund assets.
Can I refinance an existing SMSF loan to a lower rate?
Yes, refinancing is possible if the fund's LVR supports it and the benefit outweighs the cost of exiting the current loan. You will need to go through a similar application process to the original loan, including a new valuation and credit assessment.