Connected entities

Relevant transactions between related corporations or unit trust schemes are exempt from duty.

A relevant transaction is

  • a relevant reconstruction transaction – certain dutiable transactions or the acquisition of an interest in a landholder between members of a family
  • a relevant consolidation transaction – the formation of a new family by inserting a new head entity between an entity and the shareholders or unit holders of that entity.

For the purposes of this exemption, a family consists of a parent entity and its subsidiary entities. To be a subsidiary entity, the parent entity must hold 90% of the securities of that entity and control 90% of the votes at a general meeting of that entity.

See the entity restructuring fact sheet and the connected entities exemptions ruling.

Notify us of certain events that occur after a connected entities exemption is granted.

An exemption can be revoked automatically if the parent entity ceases to own and control more than 50% of the transferee within three years after the transaction (unless this is as a result of a public float or demerger). The Commissioner can also revoke the exemption if it was part of a scheme to avoid duty.

Apply for a relevant consolidation transaction exemption or a relevant reconstruction transaction exemption within 12 months after the relevant transaction.

Pre-transaction Decisions

Apply for a pre-transaction decision if you are proposing to enter into a transaction to find out

  • whether a connected entities exemption would be granted if the transaction was entered into or
  • if another transaction is entered into, whether the Commissioner would revoke a previously granted exemption for a relevant transaction.


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Page reviewed 9 October 2019