Groups formed through controlling interests for payroll tax

If a person has a controlling interest (more than 50%) in 2 or more businesses, those businesses are grouped. 'Person' includes an individual, a set of persons, a corporation, all bodies and associations (corporate, incorporated and unincorporated), and partnerships.

See the table to decide who has controlling interest for different business types.

Business type Who has controlling interest


A person who is entitled to exercise more than 50% of the voting power:

  • at director meetings


  • attached to voting shares or a class of voting shares that the corporation has issued
Body corporate or unincorporate

A person, or set of persons, who constitutes more than 50% of the management board, or controls the composition of the board


A person who:

  • owns more than 50% of the capital


  • is entitled to more than 50% of the profits


A person who is a beneficiary of more than 50% of the value of the interest in the trust that carries on the business

Under a discretionary trust, all beneficiaries are deemed to have a controlling interest

Sole owner


  • a person who is the sole business owner (whether or not as trustee)


  • a group of people who are sole owners of a business as trustee

Different business types can be grouped if the same person or set of persons has a controlling interest.


Diagram on payroll tax for controlled bodies

In this example:

  • S Pty Ltd and C Pty Ltd are related bodies corporate
  • C Pty Ltd has more than a 50% interest in A Partnership
  • S Pty Ltd has more than a 50% interest in B Partnership.

As C Pty Ltd is a subsidiary of S Pty Ltd, S Pty Ltd is also deemed to have a controlling interest of A Partnership.

In this case, S Pty Ltd, C Pty Ltd, B Partnership and A Partnership are all grouped.


Queensland Revenue Office

  • Call 1300 300 734 (Australia) or
    +61 7 3179 2500 (overseas)
  • Send an email using our online enquiry form.