Payroll Tax Grouping & Regrouping in Queensland

Queensland’s payroll tax laws group related businesses together for tax purposes based on ownership, control, common employees, or interrelated entities. This can trigger unexpected liabilities, as your combined payroll may exceed thresholds even if individual entities wouldn’t.
At Enterprise Legal, our highly experienced team advises clients across Queensland on payroll tax grouping rules, degrouping applications under section 74 of the Payroll Tax Act, and ongoing compliance strategies.
Most of our payroll tax advisory services are offered on a fixed or capped-fee basis, so you know your costs upfront. And you can easily book your initial appointment online to get started.
What We Can Help You With
- Assessing Payroll Tax Grouping Risk
We review your entities’ ownership, management, employee structure, and control links to identify if the Queensland Revenue Office may treat you as a payroll tax group. - Degrouping Applications (section 74)
We prepare and lodge applications for the Commissioner to exclude one or more entities from the group, based on operational independence. This includes managing technical submissions on ownership, employees, commercial links, control, and shared facilities. - Compliance Advice & Record Keeping
We help you structure employment, contractor payments, and trust arrangements to reduce grouping risk, and set up systems and records to support future grouping or regrouping decisions.
Why Grouping & Degrouping Matters
- Unexpected Tax Liability
Grouping can force multiple entities under one threshold. Many businesses unknowingly become liable for significant backdated payroll tax. - Joint & Several Liability
All members of a payroll tax group are jointly liable — meaning even dormant or trust entities can be held responsible for unpaid tax. - Complex Technical Triggers
The rules cover broad scenarios — including shared employees, common control, cross-ownership, and trust arrangements — meaning businesses often get grouped without realising it. - Commissioner Discretion Exists
The Commissioner has limited discretion to regroup entities that operate independently — but the process is complex and requires strong factual evidence.
Payroll Tax FAQs
Avoid surprise tax bills and get specialist payroll tax grouping and regrouping advice on a fixed-fee basis. Book your consultation online today.

What is payroll tax grouping in Queensland?
What is a degrouping application?
When should I consider degrouping?
• Before triggering serious tax liabilities
• Or after receiving group assessments from the Office of State Revenue
What factors does the Commissioner consider?
• Common employees or resources
• Financial or management links
• Business independence and commercial separation