01
Document overview
Defines the tax adjustment for fair-value investment property under a realisation-basis election, including the deduction cap and recapture.
- The realisation-basis election is irrevocable.
- Cap generally: 4% or lower TWDV.
- Land is not depreciable.
02
Scope and exclusions
Applies to
Taxable persons with fair-value investment property that make the irrevocable realisation-basis election; applies to periods from 1 January 2025.
Limitations and exclusions
Land is excluded from the depreciable base; the deduction is generally capped at the lower of 4% of original cost and 12-month tax written-down value, with recapture on disposal and related-party transfers.
05
Official primary source
Ministerial Decision No. 173 of 2025
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