- The law gives two ways to set the value at the split point: market value just before 1 July 2027, or an apportioning method set by the government.
- The apportioning method was still being developed in late 2026, so its final design is not yet known.
- The choice is made with the tax return for the year the asset is actually sold, not on 30 June 2027.
- A market valuation looks at the actual business at the date. An apportioning method is a calculation.
- Which one suits you is a tax decision for you and your accountant or tax adviser.
The split point
Under the new CGT rules, an asset held by an Australian resident individual or a trust at the end of 30 June 2027 is generally treated as sold just before 1 July 2027 and bought back on 1 July 2027. The gain up to that point keeps the old treatment, including the 50% discount. The gain after it falls under the new rules.
Nothing is payable on 30 June 2027. The split matters when the asset is eventually sold, gifted or transferred.
The amount used for that deemed sale and buy-back can be set in one of two ways.
Way one: market value at 30 June 2027
The default in the law is the asset's market value just before 1 July 2027. For a private business, or shares or units in one, there is no listed price. Market value is worked out by valuing the business itself: its earnings, its risks, its assets and the market evidence at the date.
The ATO's guidance says market value is the price a willing but not anxious buyer and seller would agree, both well informed, in an arm's length deal. It is assessed on what was known or could reasonably be foreseen at the date, not with hindsight. See what is market value for CGT.
Way two: an apportioning method
The law also lets the Minister set an apportioning method by legislative instrument. Instead of valuing the asset at the date, the method works out an amount for the split by calculation. The law says the method must take into account the buy-back on 1 July 2027 and later spending on the asset, including indexation.
A draft was released for consultation in August 2026, and the method had not been made as at 11 November 2026. The ATO said in October 2026 that the government was still developing the method and would give guidance once it is in place. So its final design, and which assets it covers, is not yet known.
When each may suit
Neither is right for everyone. In general terms:
An apportioning method may do where the asset is small relative to your affairs, the value has moved fairly steadily, or the cost of a valuation is out of proportion to what is at stake.
A market valuation may be useful where:
- the business's value moved unevenly, for example strong growth in some years and a fall in others
- something specific happened around the date, such as winning or losing a major customer or contract
- the business is a large part of your wealth, so the split carries real weight
- you want evidence of the actual position at the date, rather than an outcome driven by a formula
A calculation may use facts such as the original cost, the eventual sale price and the time held. A valuation asks a different question: what was this business actually worth on 30 June 2027? The two answers can differ, in either direction.
An independent valuation is not designed to produce a high or a low number. It sets out the most supportable market value from the evidence available.
The choice is made later
You do not have to choose on 30 June 2027. The law says the choice is made by the day you lodge your tax return for the income year in which the actual sale or other CGT event happens. That could be years away.
That timing has a practical side. If you might want to rely on market value, the evidence from around 30 June 2027 needs to exist when the choice is made. Financial statements usually survive. The commercial picture behind them, such as customer lists, pipeline, contracts and forecasts that existed at the time, often does not.
Who decides
We value. We do not give tax advice. Your accountant or tax adviser decides:
- whether the new rules apply to you, and to which assets
- whether to rely on market value or the apportioning method
- how the figure is used in your return
Our job is to independently establish the market value of the agreed business or interest, at the agreed date, for the agreed purpose.
What the valuation report covers for this purpose
- the business, shares, units or partnership interest valued, and the owner
- the date: 30 June 2027, just before 1 July 2027
- the purpose: the deemed sale and reacquisition under the new CGT rules
- market value as the standard of value
- the method, the reasons for choosing it, and a cross-check
- the earnings, adjustments and evidence relied on, and what was known at the date
- assumptions and limitations, signed by the valuer responsible
What we need from you
- the asset and the ownership structure
- financial statements up to and including the year ending 30 June 2027
- management accounts and a balance sheet at 30 June 2027
- records from around the date: customer list, contracts, pipeline, staff, budgets and known risks
Get a fixed fee
Our fee is fixed by the business's annual revenue, from $1,495 + GST for revenue under $1 million. You can book a 30 June 2027 valuation now at 10% off, and we value after the date. Choose your revenue band below to see your fee.
General information only, current at 10 November 2026. We value businesses and business interests; we do not give tax advice. Your accountant or tax adviser decides whether a rule applies to you.