New and updated rulings on relief from AFAD and land tax foreign surcharge

The Commissioner of State Revenue has issued the following 4 public rulings, effective 15 December 2025.

Public Ruling GEN012.1 Administrative arrangement—exemption from AFAD and land tax foreign surcharge for residential land developers

This new ruling sets out the terms of an administrative arrangement providing an exemption from additional foreign acquirer duty (AFAD) and land tax foreign surcharge for residential land developers undertaking residential land development.

This ruling applies to:

• AFAD liabilities arising on or after 15 December 2025
• land tax liabilities arising on or after 30 June 2026.

Public Ruling LTA000.6.1 Administrative arrangement—exemption from land tax foreign surcharge for landholders undertaking commercial activities that make a significant contribution

This new ruling sets out the terms of an administrative arrangement providing an exemption from land tax foreign surcharge for landholders undertaking commercial activities that make a significant contribution.

This ruling applies to land tax liabilities arising on or after 30 June 2026.

Public Ruling DA000.15.5 Additional foreign acquirer duty—ex gratia for significant development for liabilities arising before 15 December 2025

The title of this ruling has been amended and a new paragraph 8 inserted, setting out the date from which the guidelines in this ruling for ex gratia relief from AFAD cease to apply to AFAD liabilities.

Public Ruling LTA000.4.4 Guidelines for ex gratia relief from the land tax foreign surcharge for liabilities arising before 30 June 2026

The title of this ruling has been amended and a new paragraph 7 inserted, setting out the date from which the guidelines in this ruling for ex gratia relief from the land tax foreign surcharge cease to apply to land tax liabilities.