HUNDREDS of rural landholders on Melbourne's urban fringe have branded the Coalition a bunch of "traitors" for agreeing to Government legislation imposing a $95,000/ha tax debt on their land.

Victorian Coalition planning spokesman Matthew Guy last week said the Coalition had struck a deal with the government to exempt anyone with 10ha or less from the Growth Areas Infrastructure Contribution tax.

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But landholder group Taxed Out said the Coalition's "win" was a disaster, leaving 500 rural landholders with more than 10ha to bear the brunt of the tax.

Taxed Out spokesman Michael Hocking said landholders with 10.1ha would have the tax tied to the sale of their land, while someone on 10ha or less would pay nothing.

"This tax is immoral and we will campaign against the (Coalition) Liberals in Gembrook, Hastings and Frankston if they allow this tax to pass (through the Upper House)," Mr Hocking said.

Landholders on more than 10ha now face being trapped on their land, unable to sell to anyone but a developer, who can afford to pay the tax.

The Government wants to impose the tax to cover 20 per cent of the cost of building roads, public transport and other infrastructure in new urban growth areas.

But Mr Hocking said imposing the tax at the point of first purchase was unfair and the the Coalition had promised to vote against the GAIC tax legislation in Parliament's Upper House.

"We've always argued, and the Coalition has agreed, the GAIC should apply when the land is about to be developed (subdivided)," Mr Hocking said.

Mr Guy said he understood people were upset.

"I can only say vote Liberal and our model will be (imposing the tax) at the compliance statement stage."

But Mr Hocking said landholders felt justifiably betrayed by the Coalition.

However, there is still a chance for the Coalition to block the GAIC legislation, which has yet to pass through Victoria's Upper House.

Both sides of politics have agreed to amendments negotiated by Parliament's Disputes Resolution Committee, however Coalition Upper House leader David Davis said there was still room to negotiate further changes.