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Examples of landholder duty calculations

How to calculate duty on relevant acquisitions.

Key information

Landholder duty is payable on a relevant acquisition in a company or trust that holds Victorian land.

The calculation of duty depends on the:

  • type of landholder
  • type of acquisition
  • value of the land holdings.

Concessions and exclusions may affect how duty is calculated in some circumstances.

Calculation methods

A relevant acquisition is generally charged with duty at the same rates applying to land transfers under Chapter 2 of the Duties Act 2000 (the Act).

When the value of a landholder’s Victorian land holdings is between $1 million and $2 million, duty is calculated using the phasing-in duty formula in section 89 of the Act. 

For more details on valuation of land holdings, refer to Revenue Ruling DA-060v2 - Landholder provisions - valuation of land holdings.

Private landholders

For private companies, private unit trust schemes or wholesale unit trust schemes, different calculation methods apply depending on whether the relevant acquisition is the result of:

  • the acquisition of a single interest or aggregated interests on the same day
  • aggregated interests over time
  • a further interest.

Single interest or aggregated interests on the same day

A relevant acquisition may arise when a person acquires a significant interest in a private landholder. It may also arise where interests acquired on the same day aggregate to a significant interest.

In these circumstances, duty is calculated by multiplying the unencumbered value of the landholder’s Victorian land holdings at the date of acquisition by the percentage interest acquired as a result of the relevant acquisition.

For example, the duty payable on a relevant acquisition where a person acquires a 70% interest in a private landholder with $10 million in Victorian land holdings is calculated as follows.

  • Value of landholder's Victorian land holdings: $10 million
  • Interest acquired: 70%
  • Dutiable value ($10 million × 70%): $7 million
  • Relevant rate of duty: $110,000 plus 6.5% of the amount over $2 million
  • Duty payable on relevant acquisition ($110,000 + (6.5% × $5 million)): $435,000

Aggregated interests over time

A relevant acquisition may arise when an interest acquired by a person in a private landholder is aggregated with other interests acquired in the landholder by the person, an associated person or any other person in an associated transaction. 

In these circumstances, duty is charged on the aggregate of the amounts separately calculated for the interest acquired by the person and each of the other interests that comprise the relevant acquisition and were acquired in the 3 years preceding that acquisition.

For example, the duty payable on a relevant acquisition of a 24% interest in a landholder that is a private unit trust scheme comprising the aggregation of 4 separate 6% interests acquired over a 4-year period is calculated below. The Victorian land holdings of the landholder were valued at $8 million in the first 2 years and $10 million in the latter 2 years.

  • Value of landholder's Victorian land holdings in fourth year: $10 million
  • Interest acquired in fourth year: 6%
  • Dutiable value of interest ($10 million × 6%): $600,000
  • Value of landholder's Victorian land holdings in third year: $10 million
  • Interest acquired in third year: 6%
  • Dutiable value of interest ($10 million × 6%): $600,000
  • Value of landholder's Victorian land holdings in second year: $8 million
  • Interest acquired in second year: 6%
  • Dutiable value of interest ($8 million × 6%): $480,000
  • Value of landholder's Victorian land holdings in first year: $8 million
  • Interest acquired in first year: 6%
  • Dutiable value of interest ($8 million × 6%): $480,000
  • Dutiable value of relevant acquisition (value of fourth, third and second year interests): $1.68 million
  • Relevant rate of duty: 5.5%
  • Duty payable on relevant acquisition ($1.68 million × 5.5%): $92,400

Further interest

A relevant acquisition may arise when a person acquires a further interest in a landholder after a previous relevant acquisition has occurred. 

In these circumstances, duty on the further interest is calculated by determining the duty that would be chargeable on the prior interests acquired and the further interest, then subtracting the duty that would be chargeable on the prior interests.

The duty chargeable on the prior interests is calculated using the value of the landholder’s Victorian land holdings at the time the further interest is acquired. It is not based on the duty actually paid when the prior interests were acquired.

For example, John Citizen made a relevant acquisition of a 25% interest in a landholder that was a private unit trust scheme in June 2025. At that time, the Victorian land holdings of the scheme were valued at $10 million and the duty paid on the acquisition was $137,500 ($10 million × 25% × 5.5%).

In July 2026, John Citizen entered into an agreement and acquired a further 10% interest in the scheme. By July 2026, the value of the scheme’s Victorian land holdings had increased to $12 million. The duty payable on the acquisition of the further interest is calculated as follows:

  • Value of scheme's Victorian land holdings in August 2021: $12 million
  • Sum of further and prior interests: 35%
  • Dutiable value of further and prior interests ($12 million × 35%): $4.2 million
  • Relevant rate of duty: $110,000 plus 6.5% of the amount over $2 million 
  • Duty payable on further and prior interests ($110,000 + (6.5% × $2.2 million)): $253,000
  • Dutiable value of prior interest ($12 million × 25%): $3 million 
  • Relevant rate of duty: $110,000 plus 6.5% of the amount over $2 million
  • Duty payable on prior interest ($110,000 + (6.5% × $1 million)): $175,000
  • Duty payable on acquisition of further interest ($253,000 – $175,000): $78,000

For more information about the calculation of duty, refer to:

Public landholders

A relevant acquisition may arise in a public landholder, being a listed company or public unit trust scheme. Duty is charged at a concessional rate of 10% of the duty that would be chargeable on a transfer of all Victorian land holdings of the landholder.

Duty is calculated as if a 100% acquisition had been made in the landholder, even if the actual interest acquired is less than 100%. The duty is calculated based on the value of the land holdings of the landholder at the date of the relevant acquisition.

The concessional rate of duty does not apply to a relevant acquisition in a listed company or listed trust that has been a listed company or listed trust for less than 12 months, a declared public unit trust that has been registered as such for less than 12 months or a widely held trust that has satisfied the definition of a widely held trust for less than 12 months. In these circumstances, duty is calculated as if the relevant acquisition was made in a private landholder. 

The public landholder concessional rate of duty also does not apply where the relevant acquisition is eligible for a concessional rate of duty under section 250B or 250DI of the Act.

For example, the duty payable on a relevant acquisition where a bidder acquires 95% of the shares in a listed company under a takeover bid, when the Victorian land holdings of the scheme are valued at $20 million, is calculated as follows:

  • Value of landholder’s Victorian land holdings: $20 million
  • Deemed interest acquired: 100%
  • Dutiable value of interest ($20 million × 100%): $20 million
  • Relevant rate of duty: $110,000 plus 6.5% of the amount over $2 million
  • Duty otherwise payable on interest ($110,000 + (6.5% × $18 million)): $1.28 million
  • Concessional rate of duty payable: 10%
  • Duty payable on relevant acquisition ($1.28 million × 10%): $128,000

If the bidder subsequently acquires the remaining 5% of the shares in the company, no duty is payable in respect of this further acquisition by the bidder. This concession only extends to the bidder and not to associated persons of the bidder.

For more information about the calculation of duty, refer to:

Phasing-in formula and deduction for marketable securities duty

Where a landholder’s land holdings in Victoria are between $1 million and $2 million, duty is calculated in accordance with the formula [(A – $1 million)/$1 million] × B, where:

  • A is the unencumbered value of the land holdings in Victoria of the landholder at the time the relevant acquisition was made
  • B is the duty that, apart from the application of the formula, would be chargeable under the provisions of the Act.

A deduction is also available for any marketable securities duty paid in Victoria or another jurisdiction in Australia on the acquisition of an interest in the landholder.

For more information about the calculation of duty, refer to:

Land holdings that have entered the commercial and industrial property tax reform

Tax reform scheme land is taken into account in determining whether a company or unit trust is a landholder. However, tax reform scheme land, including land holdings relating to that land (e.g. a lease, economic entitlement or fixtures over, in or on tax reform scheme land) may be wholly or partly excluded from the calculation of duty on a relevant acquisition in the landholder.

For more information, see the exclusion of tax reform scheme land and other land holdings relating to tax reform scheme land.

Concessions relating to certain leasehold estates, fixtures and primary production land

To ensure consistency in the duty outcomes under Chapters 2 and 3 of the Act, certain concessions are available when determining the duty payable on a relevant acquisition in a landholder whose land holdings include leasehold estates, fixtures on another person's land or primary production land.

Refer to Revenue Ruling DA-055v4 - Landholder provisions: Obligations on making a relevant acquisition and duty calculation for more information on these concessions.

Updated: 9 October 2026