A general rule is that a complying SMSF is entitled to deduct from its assessable income any expenses that are

  1. incurred in gaining or producing assessable income; and
  2. necessarily incurred in carrying on a business for the purpose of gaining or producing such income.

Our understanding is that if you set up a Corporate Trustee for the sole purpose of the SMSF; in other words, its only purpose is to act as a trustee of the SMSF, then the cost is concerned to be necessarily incurred for the SMSF’s business operations.