Duties Act 1997

Section 104ZJA extends to a transfer that occurs before the commencement of that section.

The approval of a person as an exempt transferee under section 104ZJA can be given so as to apply to a transfer that occurred before the commencement of that section (a completed transfer) and if that is done the transferee is entitled to a refund of surcharge purchaser duty paid on the completed transfer before the approval was given.

If such an approval is revoked, the revocation can extend to a completed transfer with the result that surcharge purchaser duty becomes payable as if the approval had never applied to the transfer and as if liability for duty arose when revocation of the approval was notified.