Multiple property purchases (aggregation)
Where there is a series of, or multiple, transactions by the same transferee or transferee(s) who are associated persons within 12 months, these transactions may be grouped together, or aggregated, for the purposes of calculating duty.
Section 22(1) of the Duties Act 2001 provides for dutiable transactions to be aggregated and treated as a single transaction if:
- they occur within 12 months;
- the transferee is the same or the transferees are associated persons; and
- the dutiable transactions together form, evidence, give effect to or arise from what is, substantially, one arrangement relating to all of the items or parts of, or interests in, the dutiable property.
For further explanation read the Revenue Ruling - Application of Section 22 of the Duties Act 2001 (Aggregation).
Where you believe that it would not be just and reasonable to aggregate a group of dutiable transactions, you can use the Aggregation statement statutory declaration to request that the Commissioner exercise discretion to not aggregate.