Taxes Consolidation Act 1997 section 653AE

Deferral of tax on appeals under section 653J

Section 653AE provides for the repayment or deferral of residential zoned land tax (RZLT) where an appeal, judicial review or zoning change submission relating to the inclusion of a site on a local authority map remains unresolved one month before publication of a final or revised map.

• Where an appeal, judicial review or zoning change submission is unresolved one month before publication of a final or revised map, and is subsequently determined in the owner's favour by 1 February in the year of publication, the site is treated as not being a relevant site from the date the appeal was lodged or the zoning submission was made, and any RZLT paid from that date may be refunded.
• Where an appeal, judicial review or zoning change submission is unresolved by a return date, the liable person may claim a deferral of RZLT in their return pending the outcome; if the outcome favours the owner, deferred tax is not payable, but if it does not, the return must be amended and RZLT plus interest paid.
• A deferral cannot be claimed in 2025 in respect of a rezoning submission made for land on the 2025 revised map published by 31 January 2025; however, where such land appears on the 2026 revised map and the local authority notified the owner in 2025 of its decision to propose a variation but the process has not concluded by 23 May 2026, deferral may apply in 2026.
• If a liable person who has deferred RZLT sells their interest in the site before the appeal, judicial review or zoning variation process is concluded, they must amend their return and pay any RZLT and interest due.