Are audited accounts enough to value an SMSF unit trust?

Why are audited accounts at cost not enough?

Cost records what was paid for an asset, not what a willing buyer would pay at the valuation date. SMSF assets must be reported at market value, so a trust's accounts that show assets at cost do not answer the question by themselves. The ATO's guide to valuing SMSF assets says so for unlisted securities and unit trusts.

The ATO's campaign on unchanged values points the same way. SMSF Adviser reported in March 2025 that the outdated practices the ATO named included not obtaining objective data on the underlying assets of an unlisted unit trust. It also reported that in all auditor reviews finalised so far the auditor had not obtained sufficient evidence. The ATO's own initial evaluation, in its key messages of 8 July 2025, found that after its market valuation letter campaign around 45% of funds changed unlisted trust investment valuations, against around 63% for property. (SMSF Adviser reported 48% and 80% in March 2025.)

What evidence does the ATO list instead?

For unlisted securities and unit trusts, the ATO's guide lists these kinds of evidence:

• An independent valuation of the trust's assets.
• A property valuation, where property is the trust's only asset.
• The most recent arm's length sale of a unit in the trust.
• Failing those, the trustees' substantiation of the value, setting out the method and assumptions.

The ATO also says to consider a qualified independent valuer if the valuation is complex or the holding is significant.

Are audited accounts still useful?

Yes, as a starting point. The accounts show the trust's assets, liabilities and income, which is a record of what was paid and what is owed. A valuer adds what the units are worth at 30 June, which is the figure the fund's accounts need. To do that the valuer restates the assets to market value and deducts the liabilities to reach the net assets. Where property is the main asset, the property figure comes from a valuation by a registered or certified property valuer, and we value the units using it.

We value the units. Auditors decide what evidence they need, and trustees and their advisers decide what to do with the result. Investment entity, such as a unit trust that holds property, cash or listed investments: $995 + GST. Our unit trust valuation guide lists what we usually ask for.