Connected entities

Relevant transactions between related corporations or unit trust schemes are exempt from duty.
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Transaction typeWhat it involvesWhen to apply
Relevant reconstruction transactionCertain transactions between members of a family, including transfers of land, business assets or vehicle licences.Apply for an exemption within 12 months after the relevant transaction, or for a ruling on a proposed transaction.
Relevant consolidation transactionThe formation of a new family by inserting a new head entity between an entity and the shareholders or unit holders of that entity.Apply for an exemption within 12 months after the relevant transaction, or for a ruling on a proposed transaction.

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.

Notify us of certain events that occur after a connected entities exemption is granted, or request a ruling whether a future event will result in a connected entities exemption being revoked.

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 or other state taxes.

Pre-transaction decisions

Request a ruling to find out whether:

  • a connected entities exemption would be granted for a proposed transaction or
  • the Commissioner will revoke an exemption that was previously granted because of a new transaction involving the same entities.