In March 2017, Profit Ltd. purchased 50 acres of rural land in Warrnambool, Victoria. At the time the land was zoned rural, but the directors of Profit Ltd. were aware that the land would increase in value and it was likely in the future that the land would be zoned as residential. In the company documents it was stated that the land was acquired for the purpose of sheep farming. The sheep on the land were to be looked after, and the wool from the sheep to be sold to wool manufacturers.

The selling of the wool was successful at first, but by about 2019 the demand for the companys wool began to decline. In January 2020, at the next general meeting, the shareholders of Profit Ltd. decided that the wool growing business was no longer sufficiently profitable to justify the companys involvement in the business. At the same time, the land had become ripe for development as the zoning rules had changed to permit subdivision. The directors of Profit Ltd. therefore decided to take the steps required to have the land rezoned residential. To obtain council approval to subdivide the land, Profit Ltd. was required to provide sewerage services and to carry out electrical and water works, which were carried out over the next twelve months. The company was actively involved in the marketing of the land and had sold all the subdivided blocks of land at a substantial profit by June 2021.

Required: Advise Profit Ltd. of the income tax implications of the above transactions, referring to case law and sections of legislation where appropriate.

(income tax implications is related to Australia)