Video transcript for aggregated transactions webinar

[Narrator]

Hello everyone. Hopefully you can hear me. Appreciate you joining us today.

My name is Brian and I’m a Senior Revenue Officer with the Client Operations Division at the Queensland Revenue Office (QRO). I’m joined by my colleague today, Kelvin, and we’ll be discussing section 30 of the Duties Act, which deals with aggregated transactions.

Before we get started, I’ll take you through some of the functions of the webinar’s control panel. First, you’ll see an orange button with an arrow—let’s hope you do anyway. Clicking this button allows you to minimise or maximise your control panel. For audio options, you can either use your computer’s audio or listen by your phone.

If you select the computer audio option, the sound will come through your computer speakers or headphones. If you choose the phone call option, you’ll need to dial the number shown on your control panel and enter the provided codes. Please note that the system automatically mutes you during the webinar, so you won’t be able to speak to us directly.

There’s also a question pane in the control panel. As the system puts you on mute for the webinar, you won’t be able to talk to us directly during the session today. If you do have a question, we encourage you to use the question pane to interact. You simply type your question in and hit Send. We’ll be answering some questions at the end of the webinar. Alternatively, our contact details will be provided at the end of the session if you prefer that method.

This is our agenda for today. First, we’ll start with the legislation, in particular section 30 of the Duties Act. Then we’ll introduce you to the aggregation toolkit, including working a scenario through the interactive help. We’ll then quickly touch on both the transfer duty estimator and calculator. Then we’ll go through an aggregated matter where no concession is being claimed. Then we’ll go through and aggregate a matter where a home concession is been claimed on a residence. We’ll also set out how to stamp an aggregated matter. And, to finish, we’ll discuss the objection process—just in case your clients don’t agree with the decision.

As we know, transfer duty is imposed on the dutiable value of a dutiable transaction. The overall duty imposed can be affected if dutiable transactions are treated as a separate and distinct transaction, even though they are part of or form 1 agreement. Where dutiable transactions are part of the 1 agreement, section 30 ensures that the appropriate amount of duty is imposed. Without section 30, it would be possible to stage dutiable transactions over a period of time so that they appear unrelated and reduce the overall amount of duty imposed.

Relevant circumstances should be considered when determining if section 30 should apply to transactions. These include:

• the transactions are contained in one instrument
• if contained in separate instruments, any of the transactions are conditional on entry into, or completion of, any of the other transactions
• whether the parties to any of the transactions are the same or are actually related
• the timeframe over which the transactions take place
• whether, before the transactions take place, the dutiable properties were used together or dependently by the transferor or transferees
• whether, after the transactions take place, the dutiable properties are used together or dependently by the transferee or transferees.

However, these factors are not exhaustive, and each case must be considered on its own facts. More tools to assist you with aggregation are available in the toolkit.

During our presentation you’ll hear the following terms used.

• Dutiable property—it describes or lists the property that can be the subject of a dutiable transaction. Think land in Queensland business assets, etc. Refer to section 10 of the Duties Act.
• Dutiable transaction—describes or lists the transactions under which a liability for transfer duty arises. An example is an agreement for the transfer of dutiable property. It’s set out in section 9 of the Duties Act.
• ELNO workspace—a space provided by your ELNO to electronically collaborate with other transacting parties to the property settlement.
• QRO Online—it’s a secure and convenient way for self assessors to manage, lodge and pay transfer duty transactions.
• Verify—it’s a term used to ensure that the data in QRO Online matches what’s been entered in your ELNO workspace. The verify process commences in the ELNO workspace.

The section 30 toolkit brings together everything you need to know about self assessing transfer duty on aggregated transactions.

How do you find the transfer duty toolkits?

You may wish to just use a search engine and search on the term ‘transfer duty self assessors’. The screenshot on the left of the slide will show you what options you have as a self assessor. If you select Toolkits, you’ll be given 42 toolkits to select from. The aggregation toolkit is shown with the red arrow on the top right-hand side of the screen.

This is the banner page for the aggregated transactions toolkit. Here is a snapshot of what you’ll find in the toolkit. From here, you can access links to relevant public rulings and our interactive help. The interactive help will assist you in determining if aggregation may apply to your scenario based on how you answer the questions. We’ll work through a scenario shortly using the tool.

Public ruling DA030.1, which is on aggregation of dutiable transactions, provides examples of scenarios where aggregation may or may not be applicable. Additionally, there are step-by-step guides that will assist you to lodge transactions in QRO Online, depending on whether a concession is being claimed. If your matter has a concession, it’s recommended that you complete this transaction first. We’ll talk about that in a later slide.

Before starting any type of lodgement process, two critical questions must be asked.

Can this transaction be self assessed in the first place?

Aggregated transactions where more than 1 home concession is being claimed, a partial interest has been transferred with a concession or an exemption has been claimed are unable to be self assessed.

Refer to the SA1 guidelines for self assessors, available on our website, for a full list of what transactions can and can’t be self assessed. If the transaction is not able to be self assessed, then the documents will need to be sent into the Commissioner for assessing.

The second question to be asked: Is this transaction compliant with section 156D of the Duties Act?

Just because a transaction can be self assessed doesn’t automatically mean that e-conveyancing is in play. The definition of a ‘relevant transfer agreement’ requires other aggregated agreements to meet the definition of a relevant transfer agreement. Once again, the SA1 will assist you in making this decision.

There are a couple of nuances that may prevent e-conveyancing; for example, a transferee with only a single name or no surname or first name.

Up front, I want to make it clear that if you’re settling electronically there are questions completed on the transfer form and Form 24 around aggregation. If these questions are not answered correctly in your ELNO workspace, your draft QRO transaction will not be pre-filled correctly. If this occurs, you’ll need to update your ELNO workspace and select Verify. For this to work correctly, you’ll need to be out of the draft QRO transaction in QRO Online.

We’re going to work through 2 scenarios during today’s webinar.

For our first scenario, here are our given facts:

• We have a business owner signing 3 separate contracts to acquire 3 blocks of vacant land in a commercial estate from 3 different sellers.
• The contracts were all negotiated together and were signed by your client on the same day.
• You’re aware that your client intends to amalgamate the 3 blocks once ownership is obtained.
• The consideration amounts for the 3 contracts are $400,000, $500,000 and $600,000 respectively.
• The cumulative consideration is $1.5 million.

Given the way the contracts were negotiated together and the strong unity of purpose, hopefully you’re questioning whether the 3 dutiable transactions need to be aggregated.

From the aggregation toolkit page, I’ve selected the aggregated transactions sectionv30 interactive help. The banner page is being displayed. The interactive help will ask a series of questions to assist you to make the correct determination on whether to aggregate the transactions. The interactive help is an invaluable tool, and we’d encourage you to use it when deciding whether aggregation may apply.

Based on how the questions are answered, the interactive help will provide a decision on whether aggregation applies or not. If you use the interactive help, it’s recommended that you keep a screen print with your records.

Using the interactive help

Up front, we’re asked how many dutiable transactions are currently being assessed. We know that there are 3 contracts. Given each contract is a dutiable transaction, we’ll be selecting ‘more than one’ dutiable transaction. If all 3 lots were contained in the 1 contract, we’d be assessing it as 1 transaction and selecting ‘one’ dutiable transaction. Out of interest, if you selected ‘one’ dutiable transaction, you’d be asked if the purchasers or related persons have made similar purchases over an extended period. Aggregation can still apply if earlier contracts have been settled. By answering ‘yes’ to the more than 1 dutiable transaction, you’ll be asked if the properties were purchased by agreement or transfer, at auction without conditions or at auction with conditions. In our scenario the tender process was followed, so we’ll be selecting ‘by agreement or transfer’. Note that if you selected the second option—’at auction (unconditional arrangement or contract)’—aggregation would not apply if all properties were purchased at auction at the fall of the hammer. If you selected the third option—that is, ‘at auction with conditions’—aggregation might still apply. You’d be asked further questions.

If you want to read up further around aggregation and auctions, I’d encourage you to review example 7 in our public ruling DA030.1 to gain a better understanding.

We selected the ‘agreement or transfer’ for how the properties were purchased. We’re then asked if the agreements were executed or signed on the same day. In our scenario, we know that they were all signed on the same day so we will select ‘yes’ to the question. There are examples in the public ruling around aggregation applying to scenarios where the contracts were signed on different days.

We’re asked if the offers to purchase the properties were all made at the same time. Given a buyer’s agent was involved and instructions were given to the agent, we’ll answer ‘yes’ to this question.

At this stage, we’ve been asked 4 questions. You might notice that at the bottom of this slide, the word ‘Aggregate’ is appearing. The interactive help has given us an answer: that is, to aggregate.

Our scenario is somewhat similar to example 5 as set out in the public ruling DA030.1 (aggregation of dutiable transactions). In that example, a purchaser signs 5 contracts for adjoining properties with 5 separate, unrelated vendors on separate dates over a 3-month period. Each contract is conditional upon the owners of the other blocks agreeing to sell their properties. It would be considered that there is sufficient unity of purpose in the dutiable transactions for the transactions to be aggregated. The same reasoning may also apply where all the contracts are conditional on the granting of some approval by a third party organisation such as a local council.

Are you familiar with the current transfer duty rates in Queensland?

The good news is we don’t need to memorise the thresholds and the rates, given we have online calculators that will do the maths for us. Here are the current duty rates. It’s very similar to income tax rates—you get the benefit of a sliding threshold before you get to a top rate. The higher the consideration amount or unencumbered value of the property, the higher the rate of transfer duty applicable. We can see from our bottom line that for transactions over $1 million the transfer duty rate is $5.75 per $100 or part thereof plus $38,025.

With aggregation, the duty rate is calculated on the cumulative considerations for all transactions. For example, if you have 2 transactions with a cumulative consideration $1.5 million without concessions, the transfer duty rate would be assessed as one, and duty would be calculated as $38,025 plus $5.75 for each $100 over a $1 million.

Before we work through our aggregation matter, I just want to briefly touch on both our transfer duty estimator and transfer duty calculator. I’m a strong advocate of working out what the liability will be for an aggregated series of transactions before commencing entering the data into QRO Online. The estimator is the easier of the two to use; however, if you’re not doing a full transfer or if there is a mixed concession claim—or if AFAD is applicable—you need to refer to our calculator.

With the estimator, it’s as simple as making 2 selections. We need to select the property type and the consideration amount. You might recall that we said we had 3 contracts for vacant commercial land that totalled $1.5 million. By selecting ‘investment property, vacant land’ and entering the cumulative purchase price of $1.5 million, we’re given a transfer duty calculation of $66,775.

I’ll now do the same calculation using the transfer duty calculator. There is a link from the aggregation toolkit to our calculator. The calculator is divided into several parts. Let’s start with the document details. You’ll need to insert a document date. I’ve used the 26th April 2024. If there was an unconditional date, insert that date too. You’ll be asked if the transaction is a relevant transfer agreement (section 156D). If ‘yes’, you’ll be given an additional 30 days from the document date to lodge.

You’ll also be asked to enter a date when the documents will be lodged and paid. The assessment type will default to ‘self assessment’. Now select Next.

Now we move to the ‘nature of interest’ section, where 2 important aspects of the calculation are entered. The calculator will accept a 1 or a fraction, provided it equals a whole interest or less. We’re going to insert a 1 in ‘no concession’, given it’s a full transfer and no concessions are being claimed.

You’ll then be asked to enter the unencumbered value of the entire property. We’ll enter $1.5 million. We’ll also put that amount in the ‘value of any non-residential property’, although it’s not necessary in our scenario given the rates are the same for residential and commercial land.

The AFAD question will default to ‘no’. Given it’s commercial land, we don’t need to change anything as the AFAD is only potentially payable on residential land.

After entering the relevant fields, we then select Calculate. The calculator will return a transferred duty liability of $66,775. You’ll note that, unlike the estimator, we can also determine the UTI start date. You can also select Report to give you a breakdown of the calculation, which can be printed out and retained.

Let’s focus on our first scenario. Three contracts, all needed to be aggregated. We’ve established that no concessions or exemptions will apply. Before entering the details in QRO Online, you’ll need to work out the order that you want to enter the transactions. Keep in mind: if you’re settling electronically, a draft QRO transaction will be generated from information contained in your ELNO workspace. We’ve already discussed that the ELNO workspace needs to reflect that the transactions are to be aggregated.

In this scenario, we’ll go in an ascending order based on consideration. The $400,000 contract will therefore be the first in the arrangement, the $500,000 contract will be the second and the $600,000 contract will be the third and final. You get to choose what order you use.

In QRO Online, we start with the first transaction and work in a consecutive order. Keep in mind that each transaction builds on the prior transactions entered. Using both the estimator and the calculator, we’ve just determined that the transfer duty for our aggregation will be $66,775. Apart from working out the expected liability before starting, I would also recommend that you keep a running sheet (or spreadsheet) open and record each transaction. You’ll see an example of the running sheet as I work through our scenario.

Here are some facts for our first transaction in the arrangement.

• We’ve selected the $400,000 contract to be the first transaction in the aggregation.
• QRO Online will allocate a 9-digit QRO transaction [number]. For our first transaction in the aggregation, the system has allocated the transaction number 527000001.
• The first transaction in the aggregation requires no offsets—it’s the simplest transaction to enter in the aggregation.

Using the estimator or calculator, I can quickly determine that the transfer duty on $400,000 without a concession is $12,425. The duty amount on each assessed transaction is required for the transfer duty offset when we complete the next transaction in the aggregation.

Okay, we’re on to our first QRO Online transaction for the aggregation. You would have already completed the identification and document details part of the transaction. We’re now in the transaction details part, focusing on the consideration section. You’ll be asked if the consideration for the transaction is less than the unencumbered value of the property included in this transaction. Given market value was paid, we’ll answer ‘no’ to the first question.

We’ll now need to enter the consideration amount for this transaction. Note the words: for this transaction. Given we said our first contract was for $400,000, we’ll enter $400,000. The next question relates to the calculated value of 100% interest based on consideration. Given it’s a full transfer, we’ll put the consideration amount again of 400,000. The 100% interest based on consideration comes into play when we’re doing partial transfers. For example, if half or 50% of the property was being transferred for $400,000, the consideration based on 100% would be $800,000.

In part 3 of the transaction, there’s also an aggregation section.

The first question: Does the transaction form part of an arrangement that includes other dutiable transactions? That is, does aggregation apply? We’re going to answer ‘yes’.

The second question asks us if the transaction is the first transaction in the arrangement. Given it is, we’re going to answer ‘yes’. Even if we answered ‘no’ to the first question, we’d still come up with the correct calculation for the first transaction given it’s assessed by itself.

For electronic settlements, the first question will be pre-filled from data entered into the ELNO workspace. If you need to amend it, make the changes in your ELNO workspace, save the QRO Online transaction in draft, get out of the transaction and verify the transaction in your ELNO workspace. This will update your draft.

Once part 3 of the transaction is completed you can go to part 4, being the liability part. The liability of $12,425 will be displayed. Given this is the first transaction, there is no offset for transfer duty assessed on previous transactions in the aggregation.

Okay, let’s fill out the running sheet that I’ve prepared. You can see that I’ve already inserted the transaction number for the first transaction and the transfer duty liability. I’ve also inserted the total of $66,775, which we know will be the transfer duty liability for the total aggregation.

Let’s get into the second transaction in our aggregation, being our contract for $500,000.

• For the second transaction in the aggregation, the system has allocated the transaction number 527000002.
• The transfer duty amount on the first transaction of $12,425 will be the offset amount for the second transaction.
• You’ll be required to enter the consideration for the second contract and the cumulative consideration for the transactions already entered.
• For this transaction, the cumulative consideration will be $900,000—that is, the consideration for both the first and second transactions (cumulative).

So we’re back to part 3 of the transaction—this time for our second transaction. We’ll once again answer ‘no’, given the consideration amount is not less than the unencumbered value.

Next, we need to enter the consideration amount for this transaction. Focus on the words: for this transaction. The consideration for the second transaction is $500,000. Given it’s a full transfer, we’ll enter $500,000 again for the 100% of consideration question.

That brings us to the aggregation section. The first two questions that we’ve already discussed are there. For the first question, we’ll indicate that aggregation applies. For the second question, as soon as we indicate that it’s not the first transaction in the aggregation, we’re given 3 extra fields to complete.

As previously discussed, each transaction builds on the previous ones entered. We need to enter the transaction numbers that have come before this transaction. We don’t enter the transaction numbers that will follow when completing this transaction.

Going to our running sheet, we know the first transaction number was 527000001, so we can enter the number in the previous transactions field.

Next, we’re asked for the cumulative consideration assessed. Notice the word: cumulative. We need to combine the consideration of this transaction with the consideration of any previous transactions entered in the arrangement. Given we’re up to the second transaction, we will enter $900,000, being the total of $400,000 for the first transaction and $500,000 for our second transaction. We don’t include the consideration for the third transaction when we’re completing the second transaction. Remember: every transaction builds on the previous one. One step at a time.

This is a final question on the page asking if a home concession is being claimed. We’ll answer ‘no’ to this question given it’s a commercial property.

At part 4 of the transaction, the system will work out the duty on $900,000 with no concessions applied, which is $33,525. You’ll need to go in and insert less duty already assessed in prior transactions. In this case, this will be our first transaction, which will result in an offset of $12,425.

Note that if AFAD was payable, we would not offset the AFAD—just the transfer duty. The same applies for interest or penalties—the offset is only for transfer duty.

You’ll see that our liability amount for our second transaction is $21,100. Let’s go back to our running sheet and complete the details from our second transaction. The second transaction number is 527000002 and the assessed liability is $22,100.

By getting our total duty amount of $66,775 and deducting both $12,425 and $21,100, we can quickly work out that the liability for our third and final transaction should be $33,250.

Hopefully, you can see the benefits of working out the overall liability before you start.

Okay, let’s get going on our third and final transaction for this aggregation.

• The contract amount is for 600,000.
• For our third transaction, the system has allocated the transaction number 527000003.
• The transfer duty amount assessed on the first 2 transactions in the aggregation is $33,525. This amount will become our transfer duty offset when we complete the third transaction.
• You’ll be required to enter the consideration for the third contract and the cumulative consideration for this transaction and the transactions already entered.
• For this transaction, the cumulative consideration will be $1.5 million.

Okay, no surprises for the third transaction. In the consideration section, we’re only inserting the consideration amount for this transaction, being $600,000. You should be right with the first 2 questions. We know that it’s aggregated but it’s not the first transaction in our aggregation. Given we’re assessing the third transaction in the arrangement, we’ll need to insert the prior 2 transaction numbers, which we’ll get from our running sheet. The cumulative consideration assessed is for all the transactions assessed including this one—hence, we’ll enter $1.5 million.

Once again, no home concession will apply.

The system will work out the transfer duty liability based on the cumulative consideration of $1.5 million, which we know will be $66,775. No surprises there.

The offset will be the duty assessed on the previous 2 transactions, which we know from our running sheet is $33,525. We enter that amount in the offset.

That would leave a transfer duty liability of $33,250 for the third and final transaction.

For completeness, we’ll update our running sheet. Our 3 assessments will total $66,775, which we know was the liability that we were expecting.

Just a bit of trivia: if the transactions were not aggregated, the cumulative duty liability would be $48,375. By aggregating, an additional $18,400 in transfer duty is payable.

It will probably come as no surprise to you that compliance activity is undertaken to ensure the transactions that should potentially be aggregated are reviewed.

For some of you, that might have been your first aggregation. Hopefully, it wasn’t too daunting for you.

Okay, given we have a bit of confidence up, let’s do our final aggregation for this session. This time, we’ll be applying a home concession.

These are our given facts for our second scenario:

• A buyer enters into separate contracts to acquire a home for $900,000 and a vacant block of residential land next door for $300,000.
• The contracts were all signed on the same day and are conditional on each other.
• The buyer intends to build a private tennis court on the vacant land next door to the family home.
• Both sellers are related. The wife owns the residence, and the husband owns the vacant land.
• They receive taxation advice to enter into separate contracts given the ownership structure of the two lots.
• There was no reduction in the purchase price offered when the contracts were negotiated together.

Before entering the details in QRO Online, you’ll need to work out the order that you want to enter the 2 transactions. It’s recommended that if a transaction is eligible for a home concession that you make the transaction your first in the aggregation. The $900,000 contract for the home will therefore be the first. The $300,000 contract will be the second and final transaction in the aggregation.

The total consideration for the aggregation is $1.2 million. In QRO Online, start with the first transaction and work in a consecutive order. Remember each transaction builds on the one before it. It’s recommended that you use the transfer duty calculator when you have a transaction in an aggregation eligible for a home concession.

We’ll quickly do a calculation so that we know what duty should be payable. For the purposes of the calculation, I’ve used a document date of 1st April 2024 and payment date of 20th May 2024.

Your client has provided you with a home concession Form D2.1. In the nature of interest, we will therefore insert a 1 in the home concession field.

We then need to enter the unencumbered value of the entire property. Given we’re trying to work out the duty for the aggregation, will need to combine the consideration amounts. We’ll therefore be working on a cumulative consideration of $1.2 million.

In simple terms, the home concession will not apply to vacant land that’s next door to the residence. We’re going to enter $300,000 in the value of any non-residential land even though it’s technically residential land. While it’ll not impact our calculation, given the home concession benefits caps out at $350,000, it’s still a good habit to be in.

We’re provided with a transfer duty liability of $42,350.

For our first transaction in the aggregation, here are some facts:

• We’ve selected the $900,000 contract to be the first transaction in the aggregation, given a home concession has been claimed.
• For our first transaction in this aggregation, the system has allocated the transaction number 527000004.
• The first transaction in the aggregation requires no offsets—it’s the simplest transaction to enter, as we’ve already discussed.

Using the estimator or calculator, I can quickly determine the transfer duty on $900,000 with a home concession is $26,350. The transfer duty amount on each assessed transaction is required for the transfer duty offset when we complete the next transaction in the aggregation.

In the concession type, from the drop-down options you would select ‘home concession’.

By selecting a home concession, you would be required to enter a transfer date, which would be the date of settlement, and the occupation date.

We’re at part 3 of the transaction. In the consideration section, we will need to enter the consideration amount for the transaction. We’ll enter $900,000, given we’re assessing the first transaction. Once again, you’ll need the calculated value of 100% interest, which we know will be $900,000 given it’s a full transfer.

You’ll see a question: What is the unencumbered value of any non-residential land for this transaction?

We’ll leave that field blank, given the transaction is for a home and there’s not a non-residential component for this transaction.

Back to our now very-familiar aggregation questions. Remember: given it’s the first transaction in the aggregation, our selection will not impact the calculation.

We’ll answer ‘yes’ to both and move on.

Once we get to the liability section, we have a transfer duty liability of $26,350.

Once again, I’ve created a running summary for our aggregation. I’ve entered my first transaction and, in this case, the duty liability of $26,350. Using some basic maths—given I’m expecting an overall liability of $42,350—my second and final transaction should be for $16,000.

Rightio, let’s do our second and final transaction in the aggregation. Here are some facts:

• We’ve selected the $300,000 contract to be the second and final transaction in the aggregation.
• For our second transaction in the aggregation, the system has allocated the transaction number 527000005.
• The transfer duty amount on the first transaction of $26,350 will be the offset amount for the second transaction.
• You’ll be required to enter the consideration for the second contract and the cumulative consideration for the transactions already entered.
• The cumulative consideration will be $1.2 million.

We’re now up to the consideration section. Remember: at this stage we’re entering details for this transaction. We therefore insert our consideration amount of $300,000 in both consideration fields.

Okay. We should be getting good at answering these questions.

We will indicate that it’s aggregated but it’s not our first transaction in the aggregation. We will enter the first transaction number being 527000004 in the previous transactions in the arrangement field.

This time, for the question ‘Are any of the aggregated transactions claiming a home concession?’ we’re going to answer ‘yes’. Note the words: any of the aggregated transactions.

We’ll then be asked to put in the consideration for concessional property included in this aggregation. You will recall that our first transaction for $900,000 was the consideration, so let’s enter $900,000 in that field.

We have a new question: Is the concession a first home vacant land concession? We can confidently answer ‘no’ to that question. Refer to the toolkits if you’re unsure.

We then need to enter the total interest acquired for home concession. Given our buyer is claiming the home concession, we put 1 over 1 in the home concession field. The other two questions are going to be left blank.

We then end up at the liabilities page. Remember: we only offset the transfer duty assessed on previous transactions, which in this case is $26,350.

Let’s go back to our summary sheet and fill out the second row.

We’ve got to the right duty calculation of $42,350.

With multiple transaction numbers, how do you stamp the agreements?

When stamping the agreements, there are a couple of things to remember:

• Endorse each transaction with its unique transaction number—in this case, it ends with 750.
• Write ‘Section 30 applied’ underneath the Exempt box.
• For non-electronic matters, this stamp will be repeated on the Titles Queensland Form 1 in the top right corner.
• You may also like to add the other transaction numbers that are involved either above or below the stamp, as you can see numbers ending in 749 and 751 are denoted.
• It’s really important the stamp only has one transaction number denoted on it—do not write the other aggregated transaction numbers on the stamp. Refer to the SA1 for more information on endorsing.

For matters e-conveyanced, each individual Titles Queensland Form 1 will be impressed with the same details that should match what you’ve put on the agreement.

The digital stamp, however, will not reference the section 30 or the other transactions, which is why it’s important to correctly stamp the agreements.

You might recall at the start of the webinar, I mentioned that when it comes to aggregation each case must be considered on its own facts and circumstances. When you determine matters are to be aggregated, they should be. If your client has a different view they can make an application to the Commissioner to object to the assessment. Objections are reviewed by an independent and impartial team within QRO, allowing for independent decisions to be made based on all facts and circumstances known.

There are a few important things to remember:

• Objections must be made within 60 days of the assessment being made.
• Your client must base their objection on fact or law. For example, the assessment does not take into account all relevant information or if they believe the law was incorrectly applied to their circumstances.
• Objections to the law should include legislative provisions, relied upon case law, public rulings and detail how the law has been incorrectly applied to the circumstances of their case.
• Evidence to support their position should be provided.
• Objecting does not alter or delay the due date or prevent UTI or LPI from accruing. It’s sometimes more cost effective to pay the amount up front to avoid interest or penalties. And if the objection is upheld in favour of your client, a full refund will be provided.

The point I want to stress is just because the matter has been self assessed, it doesn’t mean that there are no objection rights.

Details on objection rights are included on the transaction summary statement that you provide your client or can be found on our website. The aggregation toolkit has a link to the objection process.

Watch the video of the aggregated transactions webinar.