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Recent data confirms a significant escalation in compliance activity by Revenue NSW.
Its land tax investigations increased by 83% between 2023 and 2024 – rising to 45,192 reviews and $435.9 million in additional land tax, including extra surcharge.
Our experience is that 2025 will be higher and so too will 2026 investigations.
The message is clear: enforcement activity is intensifying – you should act now.
Exemptions Under Particular Scrutiny
Revenue NSW is dedicating substantial resources to reviewing land tax exemptions, particularly where:
- Technical requirements are not strictly satisfied; or
- Supporting documentation is incomplete or inconsistent.
The burden of proof rests entirely with you, the taxpayer. A simple lack of quality evidence is a cause of substantial land tax liabilities.
Where exemptions (including Principal Place of Residence and Primary Production claims) are reviewed, authorities are requiring comprehensive evidence such as utility bills, phone records, insurance policies, lease documents, electoral registration and licence and official address histories. Even minor evidentiary gaps can result in exemptions being denied.
We are also seeing a conservative, process-driven approach adopted by authorities including the NSW Valuer General, with objections frequently disallowed where documentation is insufficient.
Reviews Cover Five Years
Importantly, Revenue NSW land tax reviews are common up to five prior years, meaning historic record-keeping is critical.
Many reviews commence well before a formal notice is issued.
Preparation Is Critical
A review of your records and compiling and keeping a due diligence defence package well before any enquiry is a must. Your current efforts covering the past 5 years is your insurance against an unexpected land tax claim.
How We Can Help
If you have:
- Received a notice of review or assessment;
- Had an exemption disallowed; or
- Claimed an exemption and wish to ensure your position is defensible,
early advice is essential.
Coleman Greig's Taxation & Superannuation Team has extensive experience managing land tax reviews and objections. Proactive engagement can significantly reduce exposure and improve outcomes.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
