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

Land Tax Audits,
Objections & Appeals (NSW)

Revenue NSW issues annual land tax assessments and conducts targeted audits of trust structures, land ownership changes and PPR exemption claims. MGS Private advises on assessments, prepares objections and manages NCAT proceedings.

Land Tax Disputes

Objecting to a land tax assessment


An objection to a NSW land tax assessment must be lodged with Revenue NSW within 60 days of the assessment date. The objection must set out the grounds on which the assessment is challenged — and must be substantively correct to have any prospect of success.

  • Challenging the classification of a trust as a “special trust” where the deed satisfies the fixed trust definition
  • Objecting to the denial of the principal place of residence exemption
  • Challenging the land value used in an assessment — requesting NSW Valuer-General review
  • Objecting to incorrect aggregation of landholdings across entities
  • Back-year assessments — challenging assessments for prior years (Revenue NSW can issue back years for up to 5 years)
  • Appeals to NCAT — Administrative and Equal Opportunity Division
  • Penalty and interest remission applications

Each year’s assessment has its own 60-day objection period. Back-year assessments must each be challenged separately — a single objection to the current year’s assessment does not cover prior years.

Most Commonly Disputed Issues

Where MGS Private typically acts

Special Trust Classification
Whether a trust is correctly classified as a “special trust” for the flat 1.6% rate is the most common land tax dispute. Revenue NSW may incorrectly classify a fixed trust as a special trust, or fail to recognise a deed amendment that changed the classification.
PPR Exemption Denied
Revenue NSW may deny the principal place of residence exemption on grounds of residency, beneficial interest, or the nature of the property. Correctly establishing legal and equitable ownership, and the occupancy facts, is critical to a successful objection.
Land Valuation Disputes
Land tax is assessed on the unimproved land value determined by the NSW Valuer-General. Where the valuation is excessive, objecting to the valuation itself — not just the land tax assessment — is the appropriate step.
Aggregation of Landholdings
Revenue NSW may incorrectly aggregate land across separate entities, pushing a landowner above the threshold and into a higher tax bracket. MGS Private analyses the ownership structure to challenge incorrect aggregation.

Disputing a NSW land tax assessment?

60-day objection period applies. Contact MGS Private urgently through your accountant or lawyer.

Still have questions?
Feel Free to Get in Touch With us
You can find us here:
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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