Corporate trustee duty statement (Form D3.2)

Corporate trustee duty under the Duties Act 2001 (Qld) (ss 205 to 229) applies when a person makes a relevant acquisition: acquiring a share interest in a corporate trustee of a discretionary trust, or in a relevant corporation for it, as part of an arrangement under which someone obtains a benefit relating to the trust property. A corporate trustee is an unlisted corporation (other than an authorised trustee corporation) that holds dutiable property, or an indirect interest in it, on trust for a discretionary trust. Section 217 requires the acquirer to lodge a corporate trustee duty statement in the approved form within 30 days after the acquisition. Form D3.2 (version 6, March 2026) is that form. It also cites s 246H, which requires an acquirer liable to additional foreign acquirer duty (AFAD) to lodge a statement in the approved form within 30 days.

When you need it

• You have bought or otherwise acquired shares in an unlisted company that is trustee of a discretionary trust holding Queensland land or other dutiable property.
• You have acquired shares in a company that itself holds shares in such a corporate trustee.
• You are claiming an exemption for the acquisition, such as a change of trustee or a family trust acquisition; QRO says the statement must still be lodged to claim it.

1. 1

   Part A - acquirer

   Give the acquirer's name, client number, ABN, correspondence address and email, and a contact person. Say whether the acquirer is a foreign person (a foreign individual, foreign corporation or trustee of a foreign trust); if so, also answer question 15.

2. 2

   Part B - transferor

   Give the transferor's name, client number, ABN and contact details.

3. 3

   Part C - the relevant acquisition

   Give the date the share interest was acquired, the number of shares acquired and the consideration actually paid. At question 10 list duty already paid (interstate marketable securities duty or transfer duty on a trust acquisition), with evidence, to claim a reduction. At question 11 give the exemption number from the guide: 1 change of trustee (s 224), 2 family trust (s 225), or 3 where transfer duty is not imposed (s 226).

4. 4

   Part D - the corporation

   Give the corporation's name and ABN, its total issued share capital, the unencumbered value of all dutiable property held directly or indirectly on trust, and the value of any AFAD residential land.

5. 5

   Part E - declaration

   An authorised person signs, declaring they are authorised by the acquirers and the information is true. Giving false or misleading information is an offence under ss 122 and 123 of the Taxation Administration Act 2001.

• Lodge within 30 days after the relevant acquisition (Duties Act s 217). QRO then issues an assessment of the corporate trustee duty.
• Send the form and documents to Queensland Revenue Office, GPO Box 2593, Brisbane Qld 4001 (form guide).
• QRO asks for the share transfer form, a copy of the trust deed and a covering letter. If no exemption is claimed, also include valuations of the shares and of the trust's assets (including goodwill), each supported by 3 years of financial statements.
• Keep records verifying the duty liability for 5 years.

• A share purchase is not always needed for a relevant acquisition; check the arrangement as a whole (QRO).
• Where the trust's business assets are used in more than one state, the dutiable value is apportioned (ss 218 to 219).
• Use the statutory declaration published for the change of trustee exemption when claiming it.