When the Federal Government confirmed the introduction of Division 296 , the policy intent appeared narrow: an additional tax on superannuation earnings for balances above $3 million , designed to raise revenue while affecting only a small proportion of Australians. What has followed is something broader and more consequential. For many high‑net‑worth Australians — and for those likely to cross the threshold in time — Division 296 has triggered a structural reassessment of wh