Compliance areas of focus 2025–26

Published on 19 November 2025

Our approach

Our compliance programs help maintain fairness and integrity in Victoria's tax system. Our expert investigative teams use advanced data-matching techniques to identify non-compliance. Each year, we improve our methods and programs to keep our success rates high. Our aim is to focus on non-compliant customers and avoid impacting those doing the right thing.

Compliance results for 2024–25

Our compliance activities in 2024–25 delivered the following results:

• More than 13,300 investigations completed resulting in $888 million in assessed tax, including $56 million in penalties.
• Over 90% of investigations identified non-compliance.
• We received 819 valid objections to assessments issued following investigations, with only 89 allowed in full. The remainder were either disallowed in full or part.
• Across all objection decisions, 22 matters proceeded to hearing, with 18 decided in favour of the Commissioner.

Compliance focus for 2025–26

We run extensive programs under each of our revenue lines. While we're focused on improving compliance across the board, the following list highlights some of our priorities in 2025–26.

Payroll tax 

Victorian employers are expected to meet their payroll tax obligations which include registering, lodging returns and paying their tax debts when due. In 2025–26, we will be focusing on:

• undisclosed wages with a strong emphasis on superannuation, fringe benefit and contactor payments
• labour hire and employment agency arrangements.

Land tax 

Landowners are expected to review their land tax assessments for accuracy and to promptly notify us of any errors or omissions. This includes their eligibility for any exemptions that may have been carried over from the previous assessment year, as well as whether they own land as a trustee or are an absentee (foreign) owner. Consequently, in 2025–26 we will be focusing on:

• land incorrectly receiving the principal place of residence or primary production exemption
• land owned by trustees and absentee owners.

Vacant residential land tax 

From 1 January 2025, vacant residential land tax was expanded to apply to residential land across all of Victoria. As a result of this, our areas of focus will include:

• vacant properties where the landowner has failed to make a notification
• properties incorrectly claiming the holiday home exemption.

Land transfer duty 

Duty is payable on all property purchases in Victoria, unless an exemption applies. In 2025–26, we will continue to focus on property transactions that have a high risk of misclassification, specifically:

• related party transactions
• exemptions and concessions relating to principal place of residence and first home purchases.

Landholder duty 

Acquisitions in companies and unit trust schemes that hold significant land assets in Victoria are subject to duty at the same rates that apply to land transfers. As a result of the recent court decision in Oliver Hume Property Funds (Broad Gully Rd) Diamond Creek Pty Ltd v Commissioner of State Revenue [2024] VSCA 175, our areas of focus will include:

• capital raisings by Victorian landholders
• offshore transactions in corporate groups that own land in Victoria.

Lease duty

The grant, transfer or assignment of a lease for consideration – whether monetary or non-monetary – may be subject to duty. To address the potential for the misinterpretation of the law, our focus will be on industries that deal in leasehold estates. Consequently, our areas of focus will include:

• transactions of leasehold estates in caravan parks and lifestyle villages
• the grant, transfer and/or assignment of leasehold estates associated with the establishment and sale of renewable energy assets.

First Home Owner Grant 

The First Home Owner Grant is available to eligible first home buyers purchasing or build a new home in Victoria. To counter the risks associated with applicants that misrepresent or intentionally disregard the eligibility requirement of the law, our focus will be on:

• applicants that have failed to meet the residency requirements or disclose a past receipt of the grant by their spouse/partner.

Voluntary disclosure

We support and assist our customers to get things right. If you think you may have made a mistake or missed something, we encourage you to contact us or make a voluntary disclosure. Significant penalty discounts apply to voluntary disclosures made prior to investigation than when we identify non-compliance.