The High Court has ruled on the ‘dominant use test’ for the primary production land tax exemption. In the recent Godolphin case, the multifactorial analysis has been confirmed with no one factor being regarded as determinative. The Court has clarified that the ‘dominant use’ requirement qualifies must be both the lands use as well as its purpose.

The land tax exemption for primary production land has been clarified where land is used for multiple purposes. The dominant use test has been interpreted as an objective assessment where profitability is not determinative.