The Queensland Government is now in caretaker mode until after the state election. Minimal updates will be made to this site until after the election results are declared.

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.