First in time, first in line: ‘First owned’ takes centre stage in duty exemption appeal

The decision in Commissioner of State Revenue v Special Situations Investing Group III, Inc [2026] QCA 98 means particular care must be taken when considering internal group restructures involving Queensland assets or landholders, as highlighted by Cullen Smythe and Brooke Gosbell.

The Queensland Court of Appeal, on 29 May 2026, handed down its judgement in Commissioner of State Revenue v Special Situations Investing Group III, Inc [2026] QCA 98. This case considers the meaning of "group companies" in a Queensland corporate reconstruction context, specifically the correct interpretation of section 407(1)(a)(i) of the Duties Act 2001 (Qld) (the Act). Background In November 2017 Special Situations made two separate acquisitions in GS Asian Venture (Delaware) LLC (GS Ve...

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Authors: Cullen Smythe, Brooke Gosbell

Published Date: 11 June 2026