Same aggregation principle, significantly different outcomes
Craig Milner and Scott Lang have published a paper on the different land tax grouping rules in each Australian state. Such rules apply to aggregate the landholdings of companies, trusts or both companies and trusts for the purposes of assessing land tax.
The paper was presented by Craig and Scott at the Tax Institute's annual State Taxes Convention held in Hobart in July 2025. It summarises the relevant land tax grouping rules in each state and then considers how those rules could apply to a series of case studies involving stapled structures, parent/holding entity and subsidiary entity structures, as well as trustees and custodians. In so doing, the paper explains how, despite seeking to protect the same aggregation principle and progressive nature of land tax, the rules in each state vary in significant ways, resulting in significantly different outcomes for landholding entities with land portfolios across Australia.
A copy of the paper can be accessed below.