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Providing tax, superannuation and trust education and precedent products
MGS Private · State Tax Services

Stamp Duty Audits,
Objections & Appeals (NSW)

Revenue NSW conducts active stamp duty audit programs targeting property transfers, corporate reconstructions and duty concession claims. MGS Private represents clients through audits, prepares objections and manages NCAT proceedings.

Stamp Duty Disputes

Revenue NSW stamp duty
audit & dispute


Revenue NSW conducts targeted audit programs focusing on duty concession claims — particularly corporate reconstruction concessions, related-party transactions, and landholder duty exposures. An audit can result in an assessment of duty, interest and penalties significantly exceeding the original amount.

  • Responding to Revenue NSW audit correspondence and requests for information
  • Preparing audit submissions — facts, law and valuation evidence
  • Challenging duty assessments — the application of duty provisions and exemptions
  • Preparing objections to duty assessments within the 60-day objection period
  • Appeals to the NSW Civil and Administrative Tribunal (NCAT)
  • Penalty and interest remission applications
  • Private ruling applications to Revenue NSW before a transaction proceeds

60-day objection period. An objection to a NSW stamp duty assessment must be lodged within 60 days of the assessment date. Late objections require an extension application — act urgently on receipt of any assessment.

Common Audit Triggers

Revenue NSW audit focus areas

Corporate Reconstruction Claims
Following the 2024 change from full exemption to a 90% concession, Revenue NSW is actively auditing corporate reconstruction applications — scrutinising related-entity relationships, the nature of the restructure, and valuation evidence.
Related-Party Transactions
Transfers of property between related parties at below-market consideration attract scrutiny — Revenue NSW may substitute market value for the stated consideration and assess duty on the higher amount.
Trust Establishment & Trustee Changes
The establishment of certain trust structures and changes in trustee are dutiable events — and Revenue NSW monitors property transfers to identify where duty has not been paid on the original establishment or subsequent changes.
Landholder Duty
Acquisitions of interests in landholder entities — companies or unit trusts holding NSW land — can trigger landholder duty even where no property is directly transferred. Revenue NSW audits acquisition structures for landholder duty exposure.

Received a Revenue NSW stamp duty audit or assessment?

Time limits apply. Contact MGS Private urgently through your accountant or lawyer.

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Level 7, 77 Castlereagh St, Sydney, 2000
Postal Address: GPO Box 512
Sydney, NSW 2001, Australia
Phone: (02) 9231 5111
Email: contact@macquariegs.com.au
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