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TOFA for real property

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Published on 01 Aug 08 by "THE TAX SPECIALIST" JOURNAL ARTICLE

This paper seeks to provide an overview of the proposed TOFA and uses that platform to examine in detail the likely application (or exclusion) of TOFA to transactions common to those involved in real property investment. The property industry engaged in extensive lobbying in recent years seeking to remove the majority of transactions entered into by its members from the TOFA regime. Consequently, this paper could in some respects be seen as an analysis of the success or otherwise of those efforts.

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Joshua Cardwell CTA
Photo of author, Joshua CARDWELL Josh Cardwell has over 30 years’ transactional consulting and compliance experience with a specialised focus on the real estate sector. He has extensive experience across inbound, outbound and domestic real estate clients, including providing advice on fund establishment, property/entity acquisitions and disposals, financing and repatriation and stapled structures. Prior to joining KPMG, Josh was Head of Real Estate Tax – Australia at PwC Australia, the Head of Mergers & Acquisitions at Greenwoods & Freehills and a Tax Partner at Deloitte. Josh was named 2019 Corporate Tax Adviser of the Year by the Taxation Institute of Australia and is a long-standing member of the Property Council of Australia’s Capital Markets Income Tax Committee. - Current at 25 August 2026
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