Duties Ruling - Aggregation

Under section 37 of the Duties Act 2008 (‘Duties Act’), dutiable transactions relating to separate items of dutiable property that together form, evidence, give effect to or arise from what is, substantially one arrangement are to be aggregated and treated as a single dutiable transaction.

The purpose of this ruling is to provide guidance as to when the Commissioner will consider that two or more dutiable transactions are taken to be substantially one arrangement.