The draft QWBA examines whether section CB 3 can apply to amounts derived from the disposal of land. It concludes that section CB 3 can apply to land sales if the disposal is part of a profit-making scheme except in cases involving land development or division. This is because specific provisions (sections CB 12 and CB 13) override the general provisions of section CB 3. 

However, CA ANZ is not convinced that section CB 3 can apply to land sales and argues that the legislative history of section CB 3 supports a different conclusion. 

CA ANZ recommends further analysis should be undertaken to ensure that the conclusion reached is accurate.