© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2012] VCAT 1984
Victorian Civil and Administrative Tribunal
2012-05-28
Original judgment source is linked above.
Taxation List - Land Tax Act 2005 - contracts of sale of land - purchasers did not take possession of land - less than 15% of purchase money paid - Commissioner's discretion to deem vendor not to be the owner of land where contract of sale made in good faith and in force - discretion not exercised - ss 15, 16.
APPLICANTS Oakbee Pty Ltd as trustee for the Notreen Investment Trust
CITATION Oakbee Pty Ltd v Commissioner of State Revenue
(Taxation) [2012] VCAT 1984
Assessment of the Applicant in matter T15/2011 is set aside.
For Applicant Mr Simon Tisher of Counsel instructed by Belleli King and Associates.
For Respondent Mr Albert Dinelli of counsel instructed by the Commissioner of State Revenue
SETTLEMENT is the date upon which the Purchaser shall become entitled to vacant possession of the property and chattels must be provided, namely upon payment of the initial deposit monies and approval of the Plan of Subdivision.
The same term applied in the Loren land contract except that, impossibly, "29th January 2008 or earlier by agreement" was stated as the DATE when the purchasers became entitled to vacant possession. 1998 was the wrong year. Entitlement to possession therefore arose more than 10 months before the contract was entered.
4. The deposit was refunded on 12/01/09 with a sales trust cheque no 848 in the amount of $500.
(1) For the purposes of this Act, a purchaser under a contract of sale of land is deemed to be the owner of the land (but not to the exclusion of any other person) if the purchaser has taken possession of the land.
(2) Subsection (1) applies whether or not the contract of sale has been completed by the transfer of the land.
(1) For the purposes of this Act, the vendor of land under a contract of sale of land is deemed to be the owner of the land (but not to the exclusion of any other person) until-
(a) the purchaser has taken possession of the land; and
(b) subject to subsection (3), at least 15% of the purchase money has been paid.
(2) Subsection (1) applies whether or not the contract of sale has been completed by transfer of the land.
(3) The Commissioner may determine that the vendor is deemed not to be the owner of the land despite the fact that 15% of the deposit has not been paid if the Commissioner is satisfied that
(a) the contract of sale was made in good faith and not for the purpose of avoiding land tax; and
(5) If the vendor and the purchaser are both deemed to be owners of the land under this part, there is to be deducted from any land tax payable on the land by the vendor any land tax on the land paid by the purchaser.
49. (1) When any agreement has been made for the sale of land, whether before or after the commencement of this Act, and whether or not the same has been completed by transfer or conveyance or not, the seller shall be deemed to remain the owner of the land for the purposes of this Act (though not to the exclusion of the liability of any other person) until possession of the land has been delivered to the purchaser and at least Fifteen per centum of the purchase money has been paid.
(2) Where in any case in which possession has been so delivered, less than Fifteen per centum of the purchase money has been paid, the Commissioner may exempt the seller from the provisions of this section if the Commissioner is satisfied that the agreement for sale has been made in good faith, and not for the purpose of avoiding tax, and the said agreement is still in force. In any such case the decision of the Comissioner shall be final and conclusive. [emphasis added]
[1] Exhibit "D" to Irene Tassone's statement dated 23 March 2012 and filed for the Commissioner.
[2] Exhibit "B" to Irene Tassone's statement dated 23 March 2012.
[3] As exhibit "D" to Irene Tassone's statement: see n. 1.
[4] The paragraph makes reference to the time which s-s 37(1) of the Act makes critical for the assessment of an "owner" of the land.
[5] See Cooper Brooks (Wollongong) Pty Ltd v FCT [1981] HCA 26; (1981) 147 CLR 297 as interpreted in R v Young [1999] NSWCCA 166; (1999) 46 NSWLR 681 at 687-688 per Spigelman CJ, D Pearce and R Geddes Statutory Interpretation in Australia 6th edn (LexisNexis, 2006), [2.31]-[2.34] and J Spigelman "Statutory interpretation: Identifying the linguistic register" [2000] NewcLawRw 1; (1999) 4 Newcastle L Rev 1.
[6] Relying on Manors of Mosman Pty Ltd v Commissioner of Land Tax (NSW) (1993) 26 ATR 164 at 170 per Smart J, upheld by the NSW Court of Appeal (1994) 34 NSWLR 94, Commissioner of Land Tax v Cam & Sons Pty Ltd [1965] HCA 13; (1965) 112 CLR 139 at 146, per Kitto, Taylor and Owen JJ and Sandhurst Golf Estates Pty Ltd v Commissioner of State Revenue (No 1) [2005] VCAT 549 per Bowman J.
[7] Being evidence, at best, of tendency (or similar fact evidence): compare s97 of the Evidence Act 2008.
Oakbee Pty Ltd
Commissioner of State Revenue
(1981) 147 CLR 297
(1999) 46 NSWLR 681
(1994) 34 NSWLR 94
(1965) 112 CLR 139