The Tax Institute welcomes the opportunity to provide comments to the State Revenue Office (SRO) in relation to draft revenue Ruling DA-047v3 Landholder duty - Duty concession on the interposition of a unit trust between stapled security holders and the stapled entities (Draft Ruling).
In the development of this submission, we have closely consulted with our Victorian State Tax Committee to prepare a considered response which represents the views of the broader membership of The Tax Institute.
The Tax Institute considers that the Draft Ruling requires further clarification regarding the application of paragraph 250DI(b) of the Duties Act 2000 (Vic) (Duties Act) and the interaction with other duty concessions.