Recently, many NSW property owners have received letters warning that from 1 January 2026, those with less than 25% ownership could lose their Principal Place of Residence (PPR) exemption for Land Tax. This has caused confusion, as plenty of our clients hold property as tenants in common with shares below 25%.
The NSW Government’s letters did not clearly explain the details of this change — who it applies to, why it exists, or how it will be implemented. To clarify, we contacted Revenue NSW directly. Their advice was as follows (though we recommend you confirm this with Revenue NSW, as there is no publicly available detailed guidance yet):
- If you live in the property as your home: In typical cases where spouses, siblings, or other family members jointly own and reside in the property, the PPOR exemption for Land Tax will continue to apply — even if one owner holds less than 25%.
- If you are not living in the property as your home: Currently, an owner with less than 25% has been able to claim the PPOR exemption if another co-owner occupies the property as their home. From 1 January 2026, this will no longer be the case. Any unrelated owner with less than 25% ownership will lose access to the exemption.
In short, the new rule mainly affects minority owners who don’t live in the property themselves but have been benefiting from another owner’s occupation.
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