For land tax purposes, the exemption under s 77(1) of the Land Tax Act 2005 (Vic) for registered caravan parks does not extend to the whole of the land merely because it is registered and operating as a caravan park. Where a caravan park is being developed in stages, only those parts of the land where civil works have been completed to the point that movable dwellings could be situated attract the exemption, together with communal infrastructure. The construction of dwellings on sites is not inconsistent with the exemption, but land where civil works are incomplete is not exempt. Taxpayers presenting an 'all or nothing' case bear the risk that, if the whole exemption is not established, they will have failed to discharge their onus under s 110 of the Taxation Administration Act 1997.
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