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— ATO compliance

What makes a valuation ATO-compliant.

The ATO does not maintain a list of approved valuers. It assesses whether a valuation is credible, independent and evidenced. This guide sets out what that means, and what happens when a value is challenged.

Updated 4 August 20267 min readWritten by a Certified Practising Valuer
CPV
Certified Practising Valuer, API member, signing the report
Evidence
Comparable sales contemporaneous with the valuation date
Independent
No interest in the outcome, no contingent fee
Reviewable
Written so another valuer could follow the reasoning

Credible, independent, and evidenced

The ATO's market valuation guidelines focus on the process rather than the credential. A valuation is more likely to be accepted where it is prepared by someone with recognised professional qualifications, where the process is documented, and where the evidence and reasoning are set out so that a third party can follow them.

In practice, the safest position is a report prepared and signed by a Certified Practising Valuer who is a full member of the Australian Property Institute, written with the methodology exposed rather than summarised.

Who can sign, and who should not

A valuation prepared by a party with an interest in the outcome carries very little weight. That includes the taxpayer, a related entity, and — in most contexts — the selling agent.

The valuer must be independent of the transaction and the taxpayer
Fees must not be contingent on the value reached
Any prior relationship with the property or parties should be disclosed
The report should name the individual valuer, not just the firm
Professional indemnity cover and API membership should be stated
In practice

Where a related-party transaction is involved, we disclose the relationship in the report rather than leaving the ATO to discover it.

The evidence that carries weight

Comparable sales are the backbone. For a retrospective valuation they must be contemporaneous with the valuation date — sales from the year of the event, not sales from today adjusted backwards. Each comparison should be adjusted explicitly for differences in land, improvements, condition and location.

Secondary evidence supports rather than replaces this: median movement data, planning records, historical listing material and photographs. A report that leans on indices alone is the most commonly challenged form of valuation we are asked to review.

What happens when a value is challenged

A challenge usually begins with a request for the valuation and the evidence behind it. If the Commissioner considers the value unsupported, an amended assessment may follow, along with interest and potentially penalties.

From there, the options are an objection, a request for a private ruling on the underlying question, or ultimately review at the AAT. Each of these is an evidentiary process, which is why the strength of the original report matters far more than the confidence with which the number was asserted.

Objection and expert evidence work

We prepare valuations and expert reports specifically for objections, private ruling applications and AAT proceedings, including independent review of an existing valuation or of the Commissioner's position.

Expert reports are prepared in the form required by the relevant code of conduct for expert witnesses, with the valuer's duty to the tribunal stated on the face of the report. We can be instructed directly or through your tax agent or solicitor.

Common questions

Does the ATO approve or accredit valuers?

No. There is no approved list. The ATO assesses whether the valuation is credible and properly evidenced, which in practice means a qualified, independent valuer applying a documented methodology.

Can we use a bank valuation?

Rarely. Mortgage valuations are prepared for a lender, on a different basis, with limited reporting and often a conservative bias. They are not written to support a taxation position.

What if the ATO already has a different figure?

We can review both the Commissioner's valuation and yours, identify where the methodologies diverge, and prepare an independent report for the objection. That review is often the quickest way to see whether a dispute is worth running.

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Related guides in this cluster.

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How a valuer reconstructs a past market and defends the number.
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SMSF
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What regulation 8.02B requires and what auditors reject.
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Deceased estates
Inherited property & date-of-death value
The two-year rule, probate evidence, and pre-1985 estates.
Read guide →

Valuation under review?

Send us the existing report and the ATO correspondence. We will tell you candidly whether the position is defensible before you spend anything on the dispute.

Get a fixed-fee quote 1300 768 862