While there has been a trend in recent years for the stamp duty
levied by the various States and Territories to be removed from
particular categories of transactions, such as transfers of
unlisted shares in companies and unlisted units in trusts, there
has also been a corresponding move by most Australian States and
Territories to widen the scope of duty on dealings in interests in
companies or trusts that hold land in the State or Territory.
In most States and Territories, this move has been a change from
a "land rich" model to a "landholder" model.
Under a "land rich" model, duty is only imposed on
a dealing in an interest in a company or trust where a certain
proportion of the assets of the relevant company or trust comprise
land. Under a "landholder" model, duty is imposed on a
dealing in an interest in a company or trust that holds land,
irrespective of what proportion of the entity's assets comprise
land, although in most cases the land held needs to be in
