RevenueSA seeks to ensure that the correct amount of tax is collected at the right time, by facilitating willing compliance, and when dealing with non-compliance, allowing for individual circumstances in the choice of remedy.

RevenueSA is aware that disputes can arise with taxpayers and their agents where different views are held about the ‘correct amount of tax and the right time for payment’. Such disputes can arise in relation to enquiries about returns, assessments, decisions or audits.

RevenueSA is concerned to reduce the incidence of dispute, recognising that disputes are costly for both RevenueSA and for taxpayers. To this end, RevenueSA is concerned to support taxpayers to determine (and pay) the right amount of tax without uncertainty or dispute.

Many of RevenueSA’s activities are aimed at preventing or minimising disputes. Such activities include maintaining an active legislative change program, publishing information on RevenueSA’s website and running information seminars and webinars.

RevenueSA is committed to applying the taxation and housing grant laws in a fair and transparent manner and enters into disputes with taxpayers in a view of the tax at stake and to avoid establishing adverse precedents.

RevenueSA seeks to handle disputes in a collaborative and non-confrontational manner, as this is most likely to result in the most efficient and effective resolution of the dispute for all parties.

As part of the collaborative approach, RevenueSA will be, and likewise expects taxpayers to deal with the dispute in an open and transparent manner with a focus on resolving the dispute.

RevenueSA will seek to articulate clearly the matter(s) in dispute and specify expected timeframes for determining the matter, with deadlines being adhered to wherever possible. In any dispute, RevenueSA will seek to establish and agree the relevant facts as quickly as possible.

Where necessary, RevenueSA will use its statutory powers in order to obtain the relevant facts and documents as quickly as possible.

Where you are dissatisfied with an assessment or a decision made by RevenueSA, in the first instance you should contact and discuss the matter with the nominated contact officer prior to escalating the matter or formally lodging an objection. Many misunderstandings can be clarified at this point, resulting in the prompt resolution of the matter or a formal objection not being required.

RevenueSA will take into account any relevant expert advice and seek to work with taxpayers to understand fully the relevant facts and law, sharing and testing the strengths and weaknesses of RevenueSA’s own arguments, and fully understanding and testing the strengths and weaknesses of the taxpayer’s arguments, before reaching a considered view on the strength of RevenueSA’s case.

RevenueSA must be satisfied that both the substance of any decision leading to dispute resolution and the way that the resolution is put into effect are fully in accordance with the law.

The outcome of RevenueSA’s dispute resolution practice is the making of a decision and/or the issue of an assessment. This in turn leads to a right of review in accordance with the Taxation Administration Act 1996, being a right to object to the Minister (the Treasurer), who may seek advice from and the Crown Solicitor or other persons.

An objection is a written notice addressed to the Minister informing the Minister that the taxpayer is dissatisfied with an assessment or decision of the Commissioner of State Taxation (the "Commissioner”). An objection must be lodged within 60 days of either the date service of the assessment or the date of notification of the decision. The Treasurer can permit an objection after the 60-day period, but not after 12 months of the decision.

The grounds of an objection must be stated fully and in detail in the notice of objection. This generally involves setting out the facts and addressing the relevant points of law where it is considered that the Commissioner may have incorrectly applied the law. The "onus of proof" rests with the taxpayer.

After considering an objection, the Minister will confirm, revoke or modify the Commissioner’s assessment or decision. The Minister will notify the taxpayer in writing of his decision, setting out the reasons for the decision.

A taxpayer who is dissatisfied with the Minister’s determination of their objection may appeal to the Supreme Court within 60 days of the Minister’s determination of the objection. The Supreme Court can permit an appeal after the 60-day period, but not after 12 months of the determination.

The taxpayer’s case on appeal is not limited to the grounds of the objection, or the reasons for the determination of the objection or the facts on which the determination was made.

Between the determination of an objection and the filing of an appeal, a taxpayer may wish to raise additional facts or matters with the Commissioner that in the view of the taxpayer may materially alter the basis of the assessment considered by the Minister.

In view of RevenueSA’s commitment to applying the taxation laws in a fair and transparent manner, where a taxpayer wishes to introduce additional information before committing to the expense of an appeal to the Court, RevenueSA will reinstitute the dispute resolution process, seeking to handle this step in the dispute in a collaborative and non-confrontational manner.

The Commissioner has no obligation to make any further assessment on the submission of any further information. However, should the facts and other matters provided require it, the Commissioner may make a reassessment.

Contact Us

What to do

Where a taxpayer is dissatisfied with an assessment or a decision made by RevenueSA, you are encouraged to discuss the matter with a RevenueSA staff member prior to formally lodging an objection. Many misunderstandings can be clarified at this point, resulting in the objection not proceeding. Should you be dissatisfied with the discussions, the next step is for the taxpayer to lodge an objection, pursuant to Section 82 of the Taxation Administration Act 1996 (the "TAA”).

Objections are to be forwarded to:

Treasurer
GPO Box 2264
ADELAIDE SA 5001

An objection is a written notice addressed to the Treasurer informing him that the taxpayer is dissatisfied with an assessment or decision of the Commissioner of State Taxation (the "Commissioner”). An objection must be lodged within 60 days of either the date on which the notice of assessment was served on the taxpayer or the date on which the taxpayer was notified of the decision. The Treasurer can permit an objection after the 60-day period, but not later than 12 months after the assessment/decision. An objection lodged after the 60-day period must state fully and in detail the circumstances concerning and the reasons for the failure to lodge the objection within the 60-day period.

The grounds of an objection must be stated fully and in detail in the notice of objection. This generally involves setting out the facts and addressing the relevant points of law where it is considered that the Commissioner may have incorrectly applied the law. References to case law or other legal references may help with your argument. The taxpayer must prove on the balance of probabilities that their case is correct; the "onus of proof" rests with the taxpayer.

Objections cannot be made on the grounds of fairness but should focus on why the assessment or decision was wrong in fact or law.

A taxpayer is not required to pay the relevant tax prior to lodging an objection. However, interest and penalty tax will continue to accrue if the taxpayer chooses not to pay the tax pending the outcome of the objection.

For more information relating to payment of an outstanding liability refer to our Objection or Appeal Lodged page.

After considering an objection, the Treasurer will confirm, revoke or modify the Commissioner’s assessment or decision. The Treasurer will notify the taxpayer in writing of his decision, setting out the reasons for the decision.

If the taxpayer is successful on objection, the overpaid tax will be refunded together with interest at the market rate from the date of payment of the tax to the date of the refund.

What to do

A taxpayer who is dissatisfied with the Treasurer’s determination of their objection may appeal to the Supreme Court within 60 days of the Treasurer’s determination of the objection, pursuant to section 92 of the TAA. The Supreme Court can permit an appeal after the 60-day period, but not after 12 months of the determination.

The taxpayer’s case on appeal is not limited to the grounds of the objection or the reasons for the determination of the objection or the facts on which the determination was made.

A taxpayer may also appeal to the Supreme Court if the Treasurer has failed to provide a determination within 90 days of lodgement of an objection. If a taxpayer decides to adopt this course of action, at least 14 days written notice must be given to the Commissioner of the intention to appeal.

As with an objection, it is the taxpayer's responsibility to prove that their case is correct; the "onus of proof" rests with the taxpayer.

50% of the relevant tax must be paid before an appeal is lodged, however, the Treasurer has the discretion to allow an appeal to proceed even though the tax has not been paid.

For more information relating to payment of an outstanding liability refer to our Objection or Appeal Lodged page.

On appeal, the Supreme Court may do one or more of the following:

• confirm or revoke the assessment or decision to which the appeal relates;
• make an alternative assessment or decision in place of the assessment or decision to which the appeal relates;
• order that the Commissioner be paid any assessed amount that is outstanding;
• make an order as to whether costs should be awarded.

If the taxpayer is successful on appeal, the overpaid tax will be refunded together with interest at the market rate from the date of payment of the tax to the date of refund.

What to do

If you do not agree with the statutory valuation referred to in the Notice of Emergency Services Levy Assessment (capital value), you may lodge an objection with the Valuer-General.

You must lodge an objection within 60 days of receiving the first rate notice from any rating authority for the financial year. An objection is a formal process and there are specific legislative requirements under the Valuation of Land Act 1971 for both you and the Valuer-General.

If you wish to lodge an objection for multiple properties or you also want to object to your site value (Land Tax), you need to complete and lodge a separate form for each value and property.

Prior to lodging a formal objection, you can seek further information or clarification by contacting the Office of the Valuer-General via Land Services SA on the below contact number.

Your objections to the statutory valuation can be directed to the Office of the Valuer-General.

If you lodge an objection, you are still required to pay your emergency services levy by the due date. If your objection results in an amendment to the value, then a refund may be issued.

What to do

Site values are determined on an annual basis by the Valuer-General as part of a general valuation and each new valuation comes into force from 1 July to 30 June of a financial year, then it is superseded by a new valuation coming into force for the following 1 July.

Section 24(1) of the Valuation of Land Act 1971 provides that an Objection to the Valuer-General cannot be lodged against a site value that is no longer in force. You cannot lodge an objection to a valuation for a previous financial year.

If you received your Land Tax Assessment for the 2020-21 and/or 2021-22 financial year(s) after 1 July 2022, you may send a request to RevenueSA for a review the site value no longer in force.

If you do not agree with the statutory valuation referred to in the Land Tax Assessment (site value) for the current financial year, you may lodge an objection with the Valuer-General.

You must lodge an objection within 60 days of receiving the first rate notice from any rating authority for the financial year. An objection is a formal process and there are specific legislative requirements under the Valuation of Land Act 1971 for both you and the Valuer-General.

If you wish to lodge an objection for multiple properties or you also want to object to your capital value (Emergency Services Levy), you need to complete and lodge a separate form for each value and property.

Prior to lodging a formal objection, you can seek further information or clarification by contacting the Office of the Valuer-General via Land Services SA on the below contact number.

Your objections to the statutory valuation can be directed to the Office of the Valuer-General.

If you lodge an objection, you are still required to pay your land tax by the due date. If your objection results in an amendment to the value, then a refund may be issued.

What to do

If you believe that the land use which has been attributed to your land on your Emergency Services Levy Notice is incorrect, you can lodge an objection in writing within 60 days after the date of service of the Notice.

Objections are to be directed to:

An applicant who is dissatisfied with the decision may appeal to the South Australian Civil and Administrative Tribunal (SACAT), pursuant to Section 9 of the Emergency Services Funding Act 1998.

If you lodge an objection, you are still required to pay your emergency services levy by the due date. If your objection results in an amendment to the land use, then a refund may be issued.

What to do

If you require an independent review of a decision in relation to a grant application, you may lodge a written notice of objection with the Treasurer, pursuant to Section 25 of the First Home & Housing Construction Grants Act 2000 (the "FH&HCG Act”).

Objections are to be forwarded to:

Treasurer
GPO Box 2264
ADELAIDE SA 5001

An objection is a written notice addressed to the Treasurer informing him that the applicant is dissatisfied with the Commissioner of State Taxation’s (the "Commissioner”) decision on a grant application. An Objection must be lodged within 60 days of the date of the notice of the Commissioner’s decision. The Treasurer can permit an objection after the 60-day period. An objection lodged after the 60-day period must state fully and in detail the circumstances concerning and the reasons for the failure to lodge the objection within the 60-day period.

The grounds of an objection must be stated fully and in detail in the notice of objection. This generally involves setting out the facts of the case and addressing the relevant points of law where it is considered that the Commissioner may have incorrectly applied the law. References to case law or other legal references may help with your argument. Objections cannot be made on the grounds of fairness but should focus on why the Commissioner's decision was wrong in fact or law.

After considering an objection, the Treasurer will make a determination to either confirm, vary or reverse the Commissioner’s decision. The Treasurer will notify the applicant in writing of his decision, setting out the reasons for the decision.

An applicant who is dissatisfied with the Treasurer’s determination may appeal to the South Australian Civil and Administrative Tribunal (SACAT) within 60 days of the Treasurer's determination of the objection (or such longer period as SACAT may allow), pursuant to Section 28 of the FH&HCG Act.

What to do

A betting operator that is dissatisfied with a reviewable decision of the Commissioner may lodge a written notice of objection with the Treasurer within 60 days of the decision, stating fully and in detail the grounds for the objection. The Treasurer can permit an objection after the 60-day period, but not later than 12 months of the decision. An objection lodged after the 60-day period must state fully and in detail the circumstances concerning and the reasons for the failure to lodge the objection within the 60-day period.

Objections are to be forwarded to:

Treasurer
GPO Box 2264
ADELAIDE SA 5001

A betting operator that is dissatisfied with a decision of the Treasurer to an objection may appeal to the Supreme Court within 60 days of the date of the Treasurer's determination. Appeals need not be restricted to the grounds of the original objection. The Supreme Court can permit an appeal after the 60-day period, but not after 12 months of the determination.

An appeal cannot be exercised unless 50% of the tax assessed (not including interest or penalty tax) that relates to the appeal has been paid.

Site values are determined on an annual basis by the Valuer-General as part of a general valuation and each new valuation comes into force from 1 July to 30 June of a financial year, then it is superseded by a new valuation coming into force for the following 1 July.

Section 24(1) of the Valuation of Land Act 1971 provides that an Objection to the Valuer-General cannot be lodged against a site value that is no longer in force.

Due to delays in issuing some land tax assessments following the changes required to implement land tax reform, the Commissioner of State Taxation and the Valuer-General have agreed to a temporary administrative arrangement to allow landowners to have site values reviewed that are not in force pursuant to the Valuation of Land Act 1971.

If a landowner receives a Land Tax Assessment for the 2020-21 or 2021-22 financial years after 1 July 2022, where the site value on the notice is no longer in force, and does not agree with the statutory site valuation referred to in the Land Tax Assessment, they may lodge a request for a review with RevenueSA. Your request must be within 60 days of receiving the first Land Tax Assessment from RevenueSA for the respective financial year.

Where the land owner receives a Land Tax Assessment for the current 2022-23 financial year, then you can lodge an objection with the Valuer-General within 60 days of the first notice and in accordance with the provisions of the Valuation of Land Act 1971. View more information on objecting to a value.

The approach for each financial year is summarised below:

A review of your Land Tax Assessment, including taking into consideration advice from the Valuer-General on the site value, is at the Commissioner of State Taxation’s discretion and will be on a case-by-case basis. The Commissioner of State Taxations’s decision to undertake a review will take into consideration, amongst other things, whether or not the delay in issuing a Land Tax Assessment resulted in you not being able to lodge the Objection with the Valuer-General prior to the end of the relevant financial year.

If, as a result of a site value review, the Valuer-General advises RevenueSA of an updated site value, the updated site value will be recorded in RevenueSA’s system and the updated site value will be used by RevenueSA for land tax purposes only. The site value on the valuation roll, which has been adopted by other rating agencies that use the value, will not be updated.

Further, as the site valuation review process is an administrative arrangement, should you disagree with the outcome of the site value review you do not have the ability to object, or seek a further review of the decision under the Valuation of Land Act 1971.

If you lodge a review you are still required to pay your land tax by the due date. If the review results in an amendment to the site value, then a refund or a new Land Tax Assessment may be issued.

When contacting us please provide your details, including your taxpayer numbers if possible.

This could be your ownership number, assessment number, SA taxpayer number, or similar. You may need to provide your vehicle details (if about motor vehicle stamp duty), property details (if about property stamp duty or a housing grant) or other information to help us identify you and help with your query.

You can reach us during business hours: 8:30am - 5:00pm (South Australian time), Monday to Friday (excluding public holidays).

Do you want to provide feedback or lodge a complaint?

You can do so via our feedback and complaints page.