NSW Land Tax PPR Exemption: The 25% Ownership Rule

Short answer

From the 2026 land tax year, NSW homeowners need to be careful with the principal place of residence exemption if the people living in the property collectively own less than 25% of it.

Revenue NSW says a principal place of residence exemption can generally only be claimed for one property per family, one principal place worldwide, and by natural persons. It also says the people occupying the property must collectively own at least 25% of the property.

This matters for family transfers, parents helping children, fractional ownership, estate planning, relationship changes and company or trust ownership. Use the NSW Land Tax Calculator to estimate ordinary land tax only after checking whether the home is actually exempt.

Why this rule creates calculator risk

Most land tax mistakes start before the calculator.

If a property is exempt as a principal place of residence, the ordinary NSW land tax estimate may be nil. If the exemption does not apply, the same land value may need to be counted with other taxable NSW land owned at midnight on 31 December.

The calculator can estimate land tax from an input land value. It cannot decide:

• whether the property is genuinely used and occupied as a principal place of residence,
• whether the occupying owners collectively meet the 25% ownership requirement,
• whether the one-family and one-worldwide-PPR restrictions are satisfied,
• whether a company, trust or foreign-person rule changes the position,
• whether transitional provisions apply.

That is why the exemption question should be checked before treating a calculator result as reliable.

What Revenue NSW says to check

Revenue NSW's current principal place of residence guidance lists four practical limits that matter for ordinary homeowners:

Revenue NSW also published examples for the 2026 land tax year. A person who lives in the property and owns 30% may be eligible on that ownership point. Two occupying owners with 15% and 20% interests may collectively meet the 25% test. A person living in the property with only 10%, where no other occupying owner lifts the collective interest to at least 25%, may not.

These examples are useful, but they are not a substitute for checking the full exemption rules.

Worked example: parent owns 90%, child lives in the home

Assume a parent and adult child buy a NSW apartment:

The child lives in the apartment, but the people occupying the property only own 10% collectively. On Revenue NSW's published examples, that ownership split is a warning sign for the PPR exemption.

If the exemption is unavailable, the land value may need to be considered for ordinary land tax. The parent may also have other NSW landholdings that affect the total assessment.

For a rough estimate, enter the best available NSW land value into the NSW Land Tax Calculator. Do not enter the apartment's full market price unless you are deliberately stress-testing with a rough proxy. For more on the right input, read Land Value vs Property Value for Land Tax.

Worked example: two occupying owners

Now assume two siblings own and live in a NSW property:

The occupying owners collectively own 35%. On the 25% ownership point alone, that looks different from the 10% example.

That still does not automatically prove the exemption. The owners would need to check the broader PPR requirements, family rule, use and occupation, ownership structure and any other relevant Revenue NSW conditions.

Common situations that need a second check

The 25% ownership rule is most likely to surprise people where ownership and occupation do not line up neatly.

Examples include:

• parents retaining most of the ownership while an adult child lives in the home,
• a child being added to title with a small percentage interest,
• one partner moving out after a relationship breakdown,
• an owner living overseas while another family member occupies the property,
• property held through a company, unit trust, family trust or special trust,
• estate or succession planning where legal ownership changes before occupation changes,
• family members trying to claim different homes as separate main residences.

These scenarios can involve tax, legal, estate planning and lending consequences beyond ordinary land tax. Treat the calculator as a modelling tool, not as an eligibility decision.

How to use the NSW calculator after checking the exemption

If the property is exempt, it generally should not be entered as taxable land for an ordinary NSW land tax estimate.

If the exemption is unavailable or uncertain:

1. Find the NSW land value or averaged land value used for land tax, not just the sale price.
2. Add other non-exempt NSW land held by the same owner where relevant.
3. Check whether ownership is individual, company, trustee or another structure.
4. Run the estimate in the NSW Land Tax Calculator.
5. Treat surcharge land tax, foreign-person rules and trust issues as separate checks if they apply.

For co-owned property, also read Joint Ownership and Land Tax in Australia, because the assessment may not be as simple as multiplying the bill by each person's title percentage.

Common mistakes

• Assuming the home is exempt because somebody in the family lives there.
• Ignoring the collective 25% ownership requirement for occupying owners.
• Claiming more than one PPR exemption within a family.
• Forgetting that NSW looks at one principal place of residence worldwide.
• Treating a company or trust-owned dwelling as if it were owned directly by a natural person.
• Using market value instead of land value in a land tax calculator.
• Treating an online estimate as a Revenue NSW exemption decision.

Sources

• Revenue NSW: land tax exemption for principal place of residence, checked 10 July 2026.
• Revenue NSW: preparing for the 2026 land tax year, checked 10 July 2026.
• Revenue NSW: land tax changes to the principal place of residence exemption, checked 10 July 2026.

General information disclaimer

This guide is general information only. It is not tax advice, legal advice, financial advice, an official Revenue NSW assessment or an exemption decision. NSW land tax outcomes can vary with ownership, occupation, family circumstances, trust or company ownership, residency, surcharge rules, transitional provisions and valuation dates. Check Revenue NSW and speak with a qualified adviser before relying on an estimate.