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Alert Status: High — Land Tax
MGS Products — Victorian Property

MGS VIC
Property Trust

The essential structure for Victorian property investors. Over 90% of investors acquire property in the wrong structure — removing critical future options. The MGS VIC Property Trust preserves your land tax threshold, unlocks SMSF co-investment, and enables stamp-duty-free ownership transfers.

At a glance
Land tax threshold
VIC OSR issues secondary assessments to unitholders — preserving individual thresholds as if owned personally
SMSF-compatible
Unit trust structure allows SMSF trustees to acquire units once the trust is debt-free — no other structure offers this
No stamp duty on transfer
Change beneficial ownership by issuing/redeeming units — no transfer duty applies when property value is under $1M
Refinancing flexibility
Convert non-deductible debt to deductible debt — a strategy unavailable with direct ownership
VIC Land Tax Threshold
Unitholders receive secondary assessments — threshold treatment equivalent to individual ownership
SMSF Co-Investment
Transfer units to your SMSF once debt is repaid — impossible via individual, company or discretionary trust
Stamp Duty Savings
No transfer duty on change of beneficial owner when unencumbered property value is under $1 million
Debt Refinancing
Refinance non-deductible personal debt by having the trustee borrow to redeem units — interest becomes deductible
The Problem

Why most VIC investors get the structure wrong


The most important issue when investing in Victorian residential real estate is flexibility — specifically, what you can do with the property in the future. Over 90% of investors acquire property in the wrong structure and permanently remove critical future options.

Individual ownership, companies, partnerships, and discretionary trusts all fail in different ways. Only a unit trust preserves all four critical pathways that define a truly flexible property investment.

MGS recommends each property be held in a separate VIC Property Trust. This maximises individual land tax thresholds, avoids CGT problems on partial sales, and enables targeted SMSF unit acquisition as individual properties become unencumbered.

Preserves All Options

All four future pathways remain open — SMSF transfer, stamp-duty-free ownership change, debt refinancing, and land tax threshold — unavailable in any other single structure.

Asset Protection

Property is held by the trustee, not the individual. Unitholders are protected from personal creditors while retaining the economic benefits of direct ownership.

Future Flexibility

The VIC Property Trust can issue ordinary and special units — suitable for joint ventures and minor development financing arrangements with third parties.

Negative Gearing Compatible

Unitholders may borrow in their own name to acquire units. Interest may be deductible while the trust provides structural benefits — the best of both worlds.

Six Critical Pathways

What the right structure unlocks


Each step below represents a strategy permanently foreclosed when property is acquired in the wrong structure. The VIC Property Trust preserves all six.

1

Transfer to a Superannuation Fund

The ability to transfer a residential investment property to an SMSF is paramount — most investors see property as "providing for retirement." If held in an individual's name, discretionary trust, hybrid trust or company, the SIS Act prohibits the SMSF trustee from acquiring the asset. A unit trust acquired from an arm's length party allows the SMSF to acquire units once the trust is debt-free and assets are not used as security.

2

Change Ownership Without Stamp Duty

Transferring a property between family members or to a trust normally incurs ad valorem transfer duty. A unit trust changes this: if the property value is below $1 million, issuing units to a new entity and redeeming from the old one does not attract transfer duty. For example, redeeming individual units and issuing to an SMSF trustee on a $900,000 property: no duty applies.

3

Refinance Non-Deductible Debt

Converting non-deductible personal debt (home loan) to deductible investment debt requires an equity position that is not direct ownership. When the trust trustee borrows to redeem units from a unitholder, the interest on that borrowing is deductible — a strategy confirmed in FCT v Roberts; Smith 92 ATC 4380. This pathway is closed to individual and company ownership.

4

Land Tax Threshold Preserved

The VIC Property Trust is not subject to the Land Tax Surcharge on Trusts when the trustee discloses unitholder identities. VIC OSR issues secondary assessments to unitholders. Where the unitholder owns no other land, no assessment is issued. Unitholders who reside in the property may also qualify for a PPOR exemption in whole or part.

5

Separate Threshold Per Property

MGS recommends each property be held in its own VIC Property Trust. This maximises each property's access to a separate land tax threshold rather than an aggregated land value; enables CGT planning if one property is sold while others are retained; and allows targeted SMSF refinancing as specific properties become unencumbered over time.

6

SMSF Salary Sacrifice Strategy

If the unitholder has borrowed personally to negative gear, the SMSF may still invest provided the trust asset is not being used as security. Over time, other assets (e.g. the family home) can be used as security, and a salary sacrifice arrangement can reduce the debt at the concessional 15% SMSF tax rate — accelerating the pathway to SMSF ownership.

Structure Comparison

VIC Property Trust vs other structures


The table below shows which structures preserve the four critical investment pathways. Only the VIC Property Trust achieves all four.

Structure Land Tax Threshold Change Owner (No Stamp Duty) SMSF Can Acquire Refinance to Deductible
VIC Property TrustRECOMMENDED ¹ ²
Company ²
Individual ³
Partnership ³
Hybrid Unit Trust ¹ ³
Discretionary Trust ¹ ³
¹ Value must be less than $1 million at time of transfer.
² SIS Act and SIS Regs require no borrowing in the company or unit trust and assets must not be subject to a charge.
³ SMSF can acquire “business real property” — residential investment property held in these structures is not eligible.
Order Your Trust

MGS VIC Property Trust Kit


Each MGS VIC Property Trust is prepared by Macquarie Group Services and includes everything required to establish the trust, comply with VIC land tax disclosure requirements, and administer the trust on an ongoing basis.

MGS recommends establishing a separate trust for each investment property — maximising land tax threshold access and preserving individual CGT and SMSF strategies for each asset.

VIC-specific: This trust is designed specifically for Victorian investment properties and the Land Tax Act 2005 (Division 2A of Part 3). NSW and WA investors should consider the respective state-specific trusts. QLD investors should obtain specific advice before using any trust structure for residential property.
What's included
  • Fully executed VIC Property Trust deed (capable of ordinary and special units)
  • Trustee minutes establishing the trust and issuing initial units
  • Unit register and unit certificates for all initial unitholders
  • VIC OSR unitholder disclosure documentation
  • Explanatory memorandum covering land tax, VIC legislation, unit administration and CGT
  • Access to MGS online portal for ongoing unit administration
VIC Property Trust
Single property trust establishment
Contact us
Pricing provided on application — discounts available for multiple trusts
Order Now Speak to a Specialist
Also available
Multiple trust package
2+ trusts — one per property
Discounted
Unit transfer documentation
Issue, redemption or transfer of units
POA
Capital gains tax, GST and other SIS Act implications need to be considered when undertaking transactions in relation to the trust. Specific advice should be obtained before proceeding with any restructure.
Common Questions

Frequently asked questions


Specific land tax and structuring advice should be sought from a qualified VIC land tax specialist.

A standard unit trust is classified as a “special trust” under the Land Tax Act 2005. Land held by a special trust attracts a surcharge rate with no threshold deduction — meaning land tax applies from dollar one. The VIC Property Trust is structured so that the trustee can disclose the identity of unitholders to VIC OSR, which triggers secondary assessments against the individual unitholders rather than the trust itself. This preserves each unitholder's individual threshold.

Provided the trust asset (the property) is not being used as security for the personal borrowing, the SMSF may invest. Over time, other assets — such as the family home — can be substituted as security for the personal borrowing. A salary sacrifice arrangement can then be used to accelerate debt repayment at the concessional 15% super tax rate, making the path to SMSF ownership faster and more tax efficient.

Technically yes — but MGS strongly recommends against it. Holding multiple properties in a single trust means: (a) land values are aggregated, reducing threshold access; (b) if one property is sold, the CGT gain realised may affect the retained property; (c) SMSF unit acquisition requires the trust to be debt-free on all assets, making it harder to achieve on a per-property basis; and (d) stamp duty savings on ownership change are harder to manage across pooled assets. One trust per property is the optimal structure.

Transferring an existing property into a trust structure can trigger CGT and stamp duty. The trust structure is most beneficial when established before the property is purchased. If you already own a property individually and wish to restructure, you must obtain specific advice on the CGT, stamp duty and land tax consequences before taking any action. Contact MGS for a consultation — in some circumstances the restructure is still beneficial, particularly where the future SMSF or refinancing strategy justifies the immediate costs.

Yes — unlike the NSW Land Tax Unit Trust (which is limited to a single class), the VIC Property Trust is capable of issuing both ordinary and special units with entitlements determined by the trustee. This may be used for introducing third parties who join the unitholders in special financing arrangements in minor developments. Note that SMSF investment must satisfy SIS Act requirements regardless of unit class.

No. Unitholders who reside in the trust property may be eligible for a PPOR (principal place of residence) exemption in whole or in part under VIC land tax legislation. The specific conditions for the exemption should be confirmed with a qualified VIC land tax specialist, as the rules for trust-held properties may differ from those for individually-held properties.

Protect your Victorian property investment

Don't close off your future options. Establish the right structure before you purchase — and keep all pathways open.

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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