The difference, line by line
Neither document is dishonest. They are built for different purposes, and the appraisal was never designed to survive a tax review.
Appraisal compared with registered valuation
Why the ATO rejects appraisals
The Commissioner’s expectation is set out in the Market Valuation Practice Instruction: a valuation for tax purposes should be undertaken by a person with the relevant qualifications, experience and knowledge, and the report should show its working. An appraisal typically fails on both counts — the author is not a qualified valuer, and the document states a figure without the evidence behind it.
The practical consequence is not usually an outright rejection letter. It is a request for further substantiation months or years later, at which point the property may have been sold, renovated or demolished, and a retrospective valuation is required anyway — at greater cost and on weaker evidence than if it had been obtained at the time.
When an appraisal is genuinely enough
We would rather tell you not to engage us than sell a report you do not need. An appraisal, or no valuation at all, is reasonable when:
What the difference costs
A standard metropolitan residential valuation starts at $440 including GST. Against that, an amended assessment on a contested cost base routinely runs to tens of thousands of dollars in additional tax, plus shortfall interest and, where the position was not reasonably arguable, penalties.
The valuation fee is also generally deductible as an element 2 incidental cost. The economics are rarely close.