You prepare the accounts. We produce the evidence.

Market value evidence for the unlisted assets in your clients' funds. One valuation per asset, per year.

$399 per asset · fixed fee · on-charge or bill the fund direct
Valuation docket · illustrativeComplete

Units in an unlisted unit trust

FundClient SMSF
Valuation date30 June
BasisMarket value
MethodUnderlying net assets
InputsNamed, dated, sourced
Second reviewCompleted
Delivered with an evidence file setting out the method, the inputs and their sources, ready to attach to the fund's audit file.
$1B+
Private market assets valued
14
Top 4 audited engagements
2018
Valuing private markets since

Valuation Desk is the SMSF service of PM Vals, which values private credit and equity under IPEV, AASB 13 / IFRS 13 and AASB 9 / IFRS 9.

Supports Fund accounts & statements Total super balance at 30 June In-house asset test The fund's audit file
The standard

What the ATO actually requires.

Narrower than most trustees assume, and wider than a number in a spreadsheet.

Reg 8.02B SISR
Market value every year

Trustees must value all fund assets at market value when preparing the fund's financial statements, for 2012–13 and every year since.

s 35C(2) SISA
Evidence on request

Trustees must give the auditor all relevant, objective and supportable evidence to substantiate the valuation, on request.

ASA 500
The auditor cannot fill the gap

The ATO states it is not the auditor's role to value fund assets or determine market value. They must obtain evidence, not create it.

No qualified independent valuer is required for a fund's accounts. The super laws only require one where a collectable or personal use asset is disposed of to a related party. Source: ATO, Guide to valuing SMSF assets, last updated 15 May 2026.

The five tests

The ATO's test, and what we hand you against it.

A file that fails one of these comes back to your desk.

The ATO's testWhat we hand you
Objective and supportable dataEvery input named, dated and sourced
Considers all relevant factorsThe factors weighed, and the ones ruled out
Undertaken in good faithNo interest in the fund or the asset
A rational and logical processOne method, applied the same way each year
Explainable to a third partyWritten out, and we answer the auditor direct
What we value

Pick the asset. See what we need.

Cash, listed securities and managed funds are easy to value. These are the ones that come back.

How we value it

From the assets held in the company and the price paid on acquisition, with the method and assumptions written out.

What we need

  • Entity financials
  • Share register
  • Constitution

Watch for

Statements carrying assets at cost are unlikely to be sufficient evidence on their own.

How we value it

From the trust's underlying assets. Widely held trusts and managed funds use the manager's published exit price.

What we need

  • Trust financials
  • Unit register
  • Trust deed

Watch for

A manager's number is a starting point, not evidence. We show the workings behind it.

How we value it

Against current rates and the borrower's position, with recoverability and any security recorded.

What we need

  • Loan agreement
  • Security docs
  • Payment history

Watch for

Loans left at cost or par plus accrued interest are exactly what auditors query.

How we value it

Where property is the only asset, the entity value follows a property valuation you or the trustee supply.

What we need

  • Entity financials
  • Property valuation
  • Deed or constitution

Watch for

We value the structure, not the bricks. We are not property valuers.

Examples

What comes back.

Pages from live engagements. Names, counterparties and commercial terms redacted.

Redacted sample: shadow credit rating summary page showing the weighted scorecard and rating conclusion.
Shadow credit ratingRating summary
Redacted sample: valuation report cover page showing the basis of valuation and the reporting date.
Valuation reportBasis & method
Redacted sample: executive summary page showing the fair value conclusion.
Executive summaryValue conclusion
Rates

Per asset, per year, quoted up front.

No hourly billing. Volume across a book gets an engagement rate.

Standard rate

One asset, one annual valuation

One unlisted asset at the fund's year end, with the evidence file.

$399
Per asset
Per annual valuation
Incl. GST
  • Market value at the fund's year end
  • Method and assumptions written out
  • Every input named, dated and sourced
  • Evidence file for the audit
  • Second reviewer before release
  • We answer the auditor's questions on it
Volume across your book? Ask for an engagement rate. Talk to us
Estimate
5 assets $1,995 incl. GST

Fixed fee per asset. No hourly billing.

How it runs

Send a list. Get the files back.

Start after year end and you'll have the files before the audits go out.

01

Send the asset list

The funds, the assets and the year end. One spreadsheet is enough to start.

Once per season
02

We collect what we need

Entity accounts, deeds, registers, loan agreements. We chase them, or take them if you hold them.

We do the chasing
03

Valued and reviewed

Market value from objective and supportable data, re-computed by a second reviewer.

Two sets of eyes
04

Files come back

One valuation and evidence file per asset, ready for the working papers.

PDF per asset
FAQ

Questions practices ask.

Who engages you, us or the trustee?

Either. Most practices engage us directly and on-charge the fee; some refer the trustee and stay out of the billing. The file's the same either way.

Does the ATO require an independent valuer for this?

No, not for a fund's accounts. The super laws only require one where a collectable or personal use asset goes to a related party. What's required is objective and supportable data the auditor can see. The ATO does recommend an independent valuer where an asset is a big slice of the fund, or where the valuation is complex, which covers most unlisted holdings.

What actually happens if the evidence is not there?

The auditor considers modifying the independent auditor's report, and must lodge an auditor/actuary contravention report where values may be misstated and the reporting criteria are met. If they can't put a number on the contravention, the ATO tells them they may report the total asset value as its maximum. One thin holding can end up reported at its full carrying amount.

The fund holds units in a private credit fund. Is the manager's number enough?

Treat it as a starting point, not as evidence. ASIC's REP 820 found wholesale funds with no valuation policy at all, and funds revaluing only when a credit trigger fired. The ATO counts entity financial statements as reliable evidence only if they're signed, audited and carry assets at market value rather than cost.

Will our auditors accept it?

The auditor checks the valuation rather than performing it, and judges whether the basis suits the asset. We document the method, inputs, sources and dates, and we'll answer questions on our own file. We can't guarantee any particular auditor's conclusion.

Do you deal with our clients?

Only if you want us to. We can work through your team, or go to the trustee direct for the documents. Tell us which at the start and we'll stay inside it.

Does every fund need this every year?

All fund assets must be valued at market value each year. If you're leaning on a prior valuation, the trustee has to assess and document that it's still appropriate. In practice an unlisted holding needs fresh support most years.

What about the property and the listed portfolio?

Listed securities take the closing price at 30 June, and widely held trusts use the manager's published exit price. We don't value real property. The ATO also says one item of evidence is rarely enough on its own, and an agent appraisal that doesn't list the comparable sales behind it generally won't do.

What is the turnaround?

Set by how fast the entity accounts arrive, not by the valuation. Send the list early and we'll work through the book rather than queue behind October.

How is it priced?

$399 per asset for one annual valuation, including GST, agreed before work starts. Volume across a book gets an engagement rate.

Send us the fund you least want to explain.

One asset, one year end. We will tell you what we need and when you will have it.

ben@pmvals.com