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What changed, and what it changes for you

We track decisions and ATO guidance as they land, and record what each one actually alters in a return. Reviewed at each update; last reviewed 10 September 2026.

Current law27 April 2026
Full Federal Court

Profit motive is out of the test

Commissioner of Taxation v Toowoomba Regional Council [2026] FCAFC 50. The Full Court unanimously allowed the Commissioner’s appeal, holding that the Grand Central Shopping Centre car park was a commercial parking station. “Commercial” means engaged in, or in the nature of, commerce — it does not require an intention to make, or be aimed at making, a profit. Logan J’s contrary finding at first instance was overturned.

What it changes: arguments that a council-run, hospital or shopping centre facility sits outside the definition because it is not operated for profit no longer hold. If you took a position on the 2025 first-instance decision — or advised a client to — it needs revisiting before your next lodgement. A facility that charges the public for parking in the ordinary course of its business is in scope.

Superseded6 February 2025
Federal Court

The first-instance decision, now overturned

Toowoomba Regional Council v Commissioner of Taxation [2025] FCA 161. Logan J found for the taxpayer, holding the shopping centre facility was not a commercial parking station because it was not operated commercially for profit. The decision prompted a wave of amended positions during 2025.

Status: reversed on appeal in April 2026. Retained here because positions taken between February 2025 and April 2026 may have relied on it.

Annual1 April 2025
Threshold

Threshold rose to $11.03

The car parking threshold for the FBT year ended 31 March 2026 is $11.03, up from $10.77 for the 2025 year. It indexes annually and is set by the Commissioner.

What it changes: the gate moves every year. A site that was outside the regime last year because the cheapest nearby station charged $10.90 may still be outside it — or may not, if that station has also raised its price. The test has to be re-run each year; it does not carry forward.

Ruling16 June 2021
effective 1 Apr 2022

TR 2021/2 replaced TR 96/26

The ATO rewrote its view of what a commercial parking station is, following the Qantas and Virgin Blue line of authority. Office, shopping centre and hospital car parks came into scope even where all-day parking is not the facility’s main purpose, and the “penalty rate” carve-out that many employers had relied on disappeared.

What it changes: a great many suburban and regional employers who had never paid car parking FBT came into the regime from 1 April 2022. If your position predates this ruling, it is almost certainly wrong.

Standing advice

Why last year’s answer is not this year’s

  • The threshold indexes every 1 April, moving the gate
  • Commercial parking stations open and close, particularly on city fringes
  • Operators change tariffs, and permit rates change more often than published boards
  • The definition itself has now moved twice in five years

A fresh survey each year is not an upsell. It is the only way the conclusion stays defensible.

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