Quick answer
A CGT valuation establishes market value at a date the Commonwealth tax law specifies, for a capital gains position reviewed by the ATO. A stamp duty valuation establishes value at the date of a dutiable transaction, for a state or territory revenue office. Same property, different dates, different reviewer, different consequences if wrong — and one report covers both only when it is scoped for both before the work starts.
Side by side
Why the dates rarely match
A dutiable transaction has one obvious date: the day the transfer happens. A CGT event often does not. An A1 disposal uses the contract date, not settlement. A deceased estate uses the date of death, which may be years before anything is transferred. Section 118-192 uses the day a former home first produced income, which no document records as an event at all. So a transfer between related parties can need a value at the transfer date for duty and a value at an entirely different date for CGT, on the same title, in the same month.
Where the two do converge
A related-party transfer at current market value is the common case where one date serves both, because the dutiable transaction and the CGT event happen together. Even then the report has to say so: a valuation addressed only to a tax agent, silent on the duty position, invites the revenue office to ask why it should be relied on. Where the transfer date is the effective date for both purposes, one properly scoped report with both purposes stated on its face is accepted for both, and costs less than two.
What a revenue office looks at that the ATO does not
State revenue offices routinely apply their own valuation processes and can substitute a figure produced by the state Valuer-General. The ATO does not have an equivalent standing valuation function for CGT purposes; it reviews the evidence you produced. Practically that means a duty valuation is being compared against another valuation, while a CGT valuation is being tested for whether its method and evidence hold up. The second is a documentation problem more than a number problem, which is why the comparable sales schedule and the methodology statement carry so much of the weight.
What can go wrong
The recurring failure is a single report, commissioned for one purpose, later reused for the other. It carries the wrong effective date, is addressed to the wrong party, states a purpose that does not match the provision being relied on, and has no assumptions covering the second use. It is not that the number is wrong; it is that the report does not say what the second reviewer needs it to say. Tell the valuer both purposes at the quoting stage and it is one report. Discover the second purpose afterwards and it is usually two.
Questions we are asked about this
Can one report cover both CGT and stamp duty?
Yes, where the dutiable transaction and the CGT event share an effective date, and only if both purposes are stated in the report. Ask for both at the quoting stage — retrofitting a second purpose afterwards usually means a second report.
Does the state Valuer-General’s figure bind the ATO?
No. They are assessments under different laws for different purposes. A Valuer-General figure is not your substantiation for a CGT cost base, and an independent CGT valuation is not an objection to a duty assessment.
Which one do I need for a transfer to a family member?
Usually both, and often at the same date. Duty is assessed on the dutiable value of the transfer; CGT is assessed with the market value substitution rule replacing whatever consideration actually changed hands.
Sources
- Market valuation for tax purposes — Australian Taxation Office
- Income Tax Assessment Act 1997 — Consolidated Act, AustLII
- Australian Property Institute — Professional Practice Standards and the CPV designation
General information about how valuations are used for tax purposes. Not tax advice and not legal advice. Your accountant, tax agent or solicitor should confirm which provision applies to your circumstances.
Written and reviewed by
Jarrad Khoury
Head of Valuations at Asset Valuations Group, where he leads the Business Valuation Services division. Over 10 years in property and business valuation. Registered Valuer in Queensland (Not Limited), Licensed Valuer in Western Australia (Not Limited), CPV through the Australian Property Institute (Not Limited), CPV and CBV through the Australian Valuers Institute, and Registered Business Valuer through the AIBB.
Last reviewed 15 September 2026 · About the practice · Editorial policy