Land tax is an often-overlooked state tax that, unlike income tax or GST, doesn’t make headlines but significantly affects property owners once certain thresholds are met. This tax is applicable when the unimproved value of land surpasses a specific amount, which varies by state. Typically, principal places of residence are exempt, but investment properties, commercial holdings, and certain rural land can be taxed.

Individuals and small businesses should pay close attention to land tax since exemptions can mean the difference between a manageable annual payment and an unexpected financial burden. A recent case in New South Wales (the Zonadi case) highlighted when land utilised for growing crops qualifies for the primary production exemption. The lessons from this case are pertinent for farmers, wine producers, and anyone managing mixed-use rural land.

The basics of land tax

All states and territories in Australia, with the exception of the Northern Territory, impose land tax. Key characteristics include:

  • Assessment Date: Typically set at midnight on 31 December of the previous year (for instance, the 2026 assessment is based on ownership and use as of 31 December 2025).
  • Thresholds: Differ across regions; in 2025, for example, the NSW threshold stands at $1,075,000, while in Victoria, it is $300,000.
  • Exemptions: Include principal places of residence, primary production land, land owned by charities, and specific concessional categories.
  • Rates: Operate on a progressive scale, with larger landholdings facing higher rates.

Land tax is distinct from council rates, which fund local services; it is a state revenue measure, payable annually and calculated on the total taxable value of land holdings.

Primary production exemption

The majority of states exempt land employed for primary production from land tax. The objective is straightforward: farmers should not be penalised with land tax for using their land to generate food, fibre, or similar goods. However, definitions of what constitutes primary production can vary.

Generally qualifying uses include:

  • Cultivation (growing crops or horticulture)
  • Animal husbandry (grazing, dairying, poultry, etc.)
  • Commercial fishing and aquaculture
  • Beekeeping

While this might seem clear-cut, the nuances lie in the purpose and manner of land use.

Lessons from the Zonadi case

The Zonadi case centred around an 11-hectare vineyard in the Hunter Valley, featuring:

  • 4.2 hectares of vines producing wine grapes
  • A cellar door and wine storage facility
  • A residence and tourist accommodation
  • Various trees, paddocks, and access ways

Throughout five land tax years in question, the taxpayer sold some grapes directly but primarily used the harvest to create wine off-site, which was then sold at the cellar door. Income was generated from both grape sales and tourist accommodation.

The NSW Tribunal was tasked with determining whether the primary use of the land was cultivation aimed at selling the produce of that cultivation (as specified in section 10AA of the NSW Land Tax Management Act).

The Tribunal’s decision was not in favour of the taxpayer. It stated:

  • The cultivation of grapes is indeed a form of primary production.
  • However, using those grapes for wine production did not meet the qualifications, as the exemption applies only when the produce is sold in its natural state. Wine is deemed a processed product.
  • While some grapes were sold directly, the majority of income came from wine sales.
  • Thus, the dominant use of the land was for cultivation to produce and sell wine, which is not exempt.

The exemption was denied, resulting in a land tax obligation for the taxpayer.

Why this matters

This case serves as a critical reminder for small businesses, especially those that blend agricultural practices with value-added activities such as processing or tourism. The distinction between primary and secondary production can decide the availability of a land tax exemption.

If a significant portion of income stems from cellar door sales, farmstay operations, or product manufacturing, the exemption could be jeopardised, even if cultivation occurs on the property.

Different rules in Victoria

Victoria adopts a more inclusive definition, recognising primary production as cultivation intended for selling produce in a natural, processed, or converted form. Therefore, grapes sold for wine production would still be classified as primary production.

The only additional requirement lies in the “use test,” which varies based on location:

  • Outside Greater Melbourne: land must primarily serve primary production.
  • Within urban regions: land must either solely or primarily engage in primary production activities.

Had the Zonadi vineyard been in Victoria, the ruling could have turned out significantly differently, likely resulting in an exemption.

State-based comparisons

Here’s a brief overview of how land tax treatment varies among the states concerning cultivation and primary production:

StatePrimary Production DefinitionKey Use TestTreatment of Processed Produce
NSWCultivation aimed at selling produce in its natural stateDominant use must be cultivation for selling natural produceWine made from grapes is not exempt
VICCultivation for selling produce in a natural, processed, or converted statePrimarily or solely, depending on locationWine, dried fruit, etc., are still exempt
QLDBroad definition, including cultivation, maintenance of animals, etc.Must be used exclusively or primarily for primary productionProcessed products accepted
SASimilar to NSW, concentrating on dominant useBased on actual and predominant useNarrower interpretation, similar risks as NSW
WAExemption applies to land used for primary production (cultivation, grazing, etc.)Owner must engage in a business of primary productionGenerally broader interpretation than NSW
TASLand used for primary production is exempt if actively in use for that purpose.Based on use as of 1 JulyBroad coverage
ACTLand tax applies solely to residential landPrimary production is not typically an issueN/A

Tips and strategies for individuals and small businesses

  1. Understand the dominant use test
    Authorities in NSW and SA assess all land uses. If financial returns from tourism or value-added services predominate, your exemption may be at risk.
  2. Document use and income streams
    Maintain records detailing land usage for cultivation, time and effort expended, and income allocation across activities. This information is vital if challenged.
  3. Consider state differences
    For those with land across different states, understand the variances in laws and regulations. Victoria and Queensland generally offer more leeway in recognizing processed or converted products.
  4. Review structures
    Utilising trusts or companies might alter liability, but exemptions hinge on the usage, not the ownership structure. Confirm your entity’s eligibility.
  5. Timing matters
    Use is evaluated as of a specific date (for example, 31 December in NSW). Authorities may review usage in the months before and after, making documentation of seasonal activities crucial.
  6. Beware of mixed uses
    Integrating a farm with accommodation or hospitality might shift the balance. Increased non-farming income may lead to higher land tax bills.

Conclusion

Australia’s land tax system can appear convoluted and inconsistent. For individuals and small businesses, particularly within farming and agribusiness, comprehending the nuances of primary production exemptions is essential. The Zonadi case highlights the delicate distinction between cultivation for sale in its natural form and cultivation feeding into a processing operation.

Key takeaways include:

  • In NSW and SA, proceed with caution if most income originates from processed products like wine, cheese, or farmstay tourism.
  • In Victoria and Queensland, the regulations are typically more accommodating, acknowledging processed or converted items.
  • Thorough documentation of use, income, and labour is critical if your circumstances are challenged.

For small landholders, having a clear understanding of actual land usage and income sources can prevent costly conflicts. If in doubt, seek advice promptly, as once the Commissioner issues a land tax assessment, it is your responsibility to prove your eligibility for an exemption. For more information, check our special offer.


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