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ITAA 1997 · ATO MVPI · API Professional Practice Standards

Retrospective Property Valuations for CGT.

A retrospective valuation establishes the market value of a property at a specific date in the past — used to set a CGT cost base, calculate apportioned gains, or substantiate the value of an inherited asset. We have prepared thousands of retrospective reports across Australia, dating back as far as 20 September 1985.

Reviewed by Senior Valuer, CPV (API) Updated 1 May 2026 9 min read

Key facts

Authority
ITAA 1997 · ATO MVPI
Earliest date
20 September 1985 (pre-CGT)
Required by
Accountants, executors, the ATO
Who can value
Certified Practising Valuer (API)
Turnaround
5 business days standard
Fee from
$440 incl. GST (residential)

What is a retrospective property valuation?

A retrospective property valuation is an independent assessment of a property's market value as at a date in the past, prepared by a Certified Practising Valuer in accordance with the Australian Property Institute's Professional Practice Standards and the ATO's Market Valuation Practice Instruction (MVPI). It uses contemporaneous comparable sales, current physical inspection, and historical records to produce a defensible figure that can support a CGT calculation, an estate distribution or a transfer between related parties.

"Where a market valuation is required for taxation purposes, the Commissioner expects the valuation to be undertaken by a person with the relevant qualifications, experience and knowledge."
— ATO Market Valuation Practice Instruction (MVPI)

The legal framework

Three layers of authority govern retrospective valuations for tax purposes. Each shapes a different aspect of the report — what counts as market value, when an independent valuer must be engaged, and how the ATO assesses the result.

  • ITAA 1997 s110-25 / s116-30 — establish the cost base and capital proceeds rules, including market value substitution.
  • ITAA 1997 s118-192 — the 'home first used to produce income' rule that deems acquisition at market value when a former home becomes a rental.
  • ATO Market Valuation Practice Instruction (MVPI) — the practical expectations for documentation, methodology and qualifications.
  • API Professional Practice Standards (PS, ANZVTIP) — the technical standards every CPV must follow when issuing a report.

When is a retrospective valuation required?

Retrospective valuations are needed whenever the ATO needs market value at a date other than the sale date. The most common triggers we see are:

  • Property purchased before 20 September 1985 that has changed character or use after that date.
  • A main residence first used to produce income (s118-192 ITAA 1997).
  • Inheritance — establishing date-of-death market value to reset the beneficiary's cost base.
  • Change in trust deed, ownership structure or in-specie SMSF contribution.
  • Family law settlements requiring historical asset values.
  • GST margin scheme valuations as at 1 July 2000.

Evidence we use to value the past

Retrospective valuations rely on contemporaneous evidence — sales that settled within a reasonable window of the effective date, current physical inspection where possible, and historical records describing the property's condition at the date in question. Our typical methodology layers:

  • Sales evidence from RP Data, Pricefinder and APM going back to 1985.
  • Council records, planning approvals and historical aerial photography.
  • Original purchase contracts, prior valuations and renovation records you provide.
  • Adjustment for time, location, land area, condition and improvements.

Real estate appraisal vs registered valuation

The ATO does not accept agent appraisals as substantiation for material CGT positions. The table below summarises the key differences.

Aspect Real estate appraisal Registered valuation
Author Real estate agent Certified Practising Valuer (API)
Independence Conflicted (seeks listing) Independent — no relationship to property
Methodology Marketing opinion Direct comparison + capitalisation, fully evidenced
Comparable schedule Optional Required, with addresses and adjustments
ATO acceptance Not accepted Accepted as substantiation
Professional liability None for valuation Held by valuer's PI insurer

ATO-compliant report format

Every retrospective valuation we issue follows API Professional Practice Standards and the ATO MVPI. The report is structured so your accountant can lodge it with confidence and so the valuation withstands ATO review or objection.

  • Property identification and inspection summary.
  • Statement of valuation methodology and assumptions.
  • Schedule of comparable sales with full address and adjustment matrix.
  • Signed certification by a Certified Practising Valuer.
  • Statement of qualifications and limitations.

How it works — five steps

  1. 1

    Brief & quote

    Email the property address, the relevant date, and a short note on the purpose. We return a fixed-fee quote within 2 business hours for retrospective valuations.

  2. 2

    Inspection

    A Certified Practising Valuer (API) attends the property for an internal and external inspection. Tenanted properties are coordinated directly with the occupier.

  3. 3

    Comparable sales analysis

    We research settled sales using RP Data, Pricefinder, APM and council records, applying the direct-comparison and (where relevant) capitalisation approaches.

  4. 4

    Report drafting

    The report is drafted to API Professional Practice Standards and the ATO Market Valuation Practice Instruction (MVPI), with full comparable schedules and signed certification.

  5. 5

    Delivery

    The signed PDF is delivered to you and (on request) directly to your accountant, solicitor or auditor within 5 business days of inspection.

Glossary

Plain-English definitions of the terms used in this report and in related ATO guidance.

Pre-CGT asset
An asset acquired before 20 September 1985 that is generally exempt from capital gains tax — but may become taxable on changes of character, majority underlying ownership, or use.
Cost base
Defined in Division 110 of the ITAA 1997. The amount used to calculate a capital gain, comprising acquisition cost, incidental costs, holding costs, capital improvements and title costs.
Market value substitution rule
Section 116-30 ITAA 1997 — substitutes market value for the actual capital proceeds where the parties did not deal at arm's length or there was no consideration.
MVPI
ATO Market Valuation Practice Instruction — the Commissioner's published guidance on what constitutes a defensible valuation for tax.
API
Australian Property Institute — the professional body governing valuers, including the CPV designation and the Professional Practice Standards.
Direct comparison approach
The principal valuation method for residential and most owner-occupied property — analysing comparable settled sales and adjusting for differences.
Capitalisation approach
Used for income-producing property — net market rental capitalised at a yield derived from comparable investment sales.

FAQs

Retrospective valuation questions, answered.

The questions clients, accountants and advisers ask us most often.

We routinely value to 20 September 1985 — the start of the CGT regime. Earlier dates are possible (we have prepared 1970s valuations for legacy estate work) where sufficient sales evidence and property records exist.

Yes, where possible. A current physical inspection combined with historical evidence (photos, plans, contracts, renovation records) is the methodology accepted by the ATO and the API. Where the property has been demolished or substantially altered, a desktop methodology is used and clearly documented.

Yes, when prepared by a Certified Practising Valuer following the ATO MVPI and API Professional Practice Standards. Our reports are designed to satisfy ATO review and have been used successfully in private rulings and objections.

No. The ATO explicitly distinguishes between an agent appraisal and a market valuation. Only a qualified valuer's report is accepted as substantiation for material CGT positions.

Standard turnaround is 5 business days from inspection. Urgent 48-hour reports are available for an additional fee. Complex commercial or rural retrospectives can take 7–10 business days.

Standard residential retrospective valuations start at $440 incl. GST. Pricing reflects property type, location, the effective date and the depth of historical research required. All fees are fixed and quoted upfront.

Yes — residential, commercial, industrial, retail and rural. Commercial and rural reports incorporate both direct comparison and capitalisation analysis.

Yes. We can address the report to you, your accountant, your solicitor, or all parties jointly. Direct delivery to your adviser is included at no extra cost.

Our valuers stand behind every report and provide written responses to ATO queries at no charge. Where required, we can issue a supplementary letter or expanded report addressing specific points raised.

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Need a retrospective valuation?

Fixed fees, 5-day standard turnaround, ATO-compliant reports back to 1985.

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