Portfolio Bonds & PPLI
A Tax-Efficient Investment Structure for Long-Term Wealth Building in Australia
Rather than dealing with:
– high taxes on investments in Australian brokerage accounts (up to 45% tax)
– or within superannuation(15% tax + contribution caps and restricted access until age 60),
many individuals instead choose instead to build their wealth by saving within investment structures known as Portfolio Bonds or PPLI.
What Is a Portfolio Bond?
A Portfolio Bond, or sometimes referred to as PPLI (Private Placement Life Insurance) is a life assurance policy often based in a tax-neutral jurisdiction.
It can allow you to build a customised investment portfolio in a tax-deferred environment.
Despite the word “bond,” it is not a debt instrument. Instead, it’s an insurance-based investment structure that provides flexibility in investment choice, liquid access, and potential tax & estate planning benefits for various jurisdictions around the world.
This is often a particularly appealing structure for Australians or those planning to move to Australia.

Key Benefits for Australia
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Tax-deferred investment growth
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Efficient estate planning
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Control over the timing of tax events
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Gross fund roll-up (generally no tax on investment gains inside the wrapper)
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Tax-free withdrawals after 10 years if certain rules are met
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Wide range of investment options such as funds, equities, ETFs
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Can be assigned or inherited to provide certain tax planning benefits
Why Consider This as an Australian or Future Australian Tax Resident?
Offshore bonds are attractive due to Section 26AH of the Australian Income Tax Assessment Act 1936, which offers favourable treatment for “eligible policies.”
If certain conditions are met, investment gains from such a policy can be withdrawn entirely tax-free after 10 years, even if you are or become an Australian tax resident.
The 10-Year Tax Rule in Australia
Policy Duration (Years) |
Assessable Gain on Withdrawal |
Less than 8 |
100% |
Between 8 and 9 |
66.6% |
Between 9 and 10 |
33.3% |
10 or more |
0% (tax-free) |
Rules for Top-Ups: The 125% Contribution Rule
To maintain tax-free status:
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Any year’s contribution or top up to the account must not exceed 125% of the previous year’s contribution
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If exceeded, the 10-year tax-free clock starts over from that point
Onshore v Offshore Bonds:
Investment bonds issued by Australian providers are usually taxed at the corporate rate of 30% before earnings are reinvested.
For Australian residents with a marginal tax rate above 30%, these onshore bonds can be a relatively tax-efficient way to invest long term.
However, if you have the ability to access offshore investment bonds through a tax-neutral jurisdiction, such as Hong Kong the benefits can be significantly greater.
Offshore bonds grow free from Australian tax while invested (a feature known as gross fund roll-up) allowing compounding returns to accumulate without annual tax drag.
This makes offshore bonds a powerful structure for long-term investors, especially those planning to move to or retire in Australia.

Tax Efficiencies Compared: Onshore v Offshore Bonds
Feature |
Onshore Bond |
Offshore Bond |
Tax on Investment Growth |
30% corporate tax |
0% (gross roll-up) |
10-Year Rule Applies |
Yes |
Yes |
Flexibility in Assets and Currency |
Limited |
Broad and multi-currency |
Tax-Free Switching of Assets |
Yes |
Yes |
Example
Two investors each contribute AUD 200,000 and earn 7% annual returns:
After 10 years: Offshore investor outperforms by AUD 70,740
After 20 years: Offshore investor outperforms by AUD 253,294
This advantage comes from the gross fund roll-up effect of the offshore bond.
Flexibility and Access
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You can set up regular withdrawals, ad hoc redemptions, or fully surrender the plan
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You control when tax events occur
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Withdrawals after year 10 are completely tax-free in Australia

Generational Wealth Planning
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Passing on the Tax Benefits: Through having multiple lives assured the portfolio bond can be passed on and the tax advantages for Australia potentially inherited along with the value of the assets.
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Bypassing probate: Assets held in an offshore portfolio bond can often be transferred to beneficiaries without going through the probate process, reducing delays and administrative costs in Australia.
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Simplified estate settlement: The structure allows for direct assignment to heirs, streamlining the transfer of wealth and minimizing legal complexities.
Investment Flexibility
Access a wide variety of investment options, including:
Suitability
This structure may be ideal for:
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Australians living overseas who plan to return
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Current residents seeking long-term, tax-efficient investments
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Investors needing flexibility in estate and succession planning
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High-net-worth individuals looking for compounding without tax drag
Summary: Key Takeaways
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Certain Offshore Portfolio Bonds are ATO-compliant and designed for long-term tax efficiency
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Withdrawals become tax-free after 10 years for eligible policyholders
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Gross fund roll-up allows more efficient compounding than onshore accounts
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Flexibility, control, and multi-currency investment access are key features
Want More Information?
Speak with a licensed adviser who specialises in Australian tax and cross-border planning to explore if an offshore investment bond is right for you.
Oreana Financial Services: A Licensed Financial Firm
In Hong Kong we are licensed by the Securities and Futures Commission (license no. AHX191), the Insurance Authority (license no. FB1443) and the Mandatory Provident Fund Authority (license no. IC000563).
In Australia we are licensed by the Australian Securities and Investments Commission (AFSL No: 482234, ABN 91 607 515 122).
General Advice Warning
This advice may not be suitable to you because it contains general advice that has not been tailored to your personal circumstances. Please seek personal financial and tax/or legal advice prior to acting on this information.
Before acquiring a financial product, a person should obtain a Product Disclosure Statement (PDS) relating to that product and consider the contents of the PDS before making a decision about whether to acquire the product.
The material contained in this document is based on information received in good faith from sources within the market, and on our understanding of legislation and Government press releases at the date of publication, which are believed to be reliable and accurate. Opinions constitute our judgment at the time of issue and are subject to change. Neither, the Licensee or any of the Oreana Group of companies, nor their employees or directors give any warranty of accuracy, nor accept any responsibility for errors or omissions in this document.