12.1. Jane attends her GP's surgery. Her GP is satisfied with the results of the physiotherapy.

Consultation: Jane only; or both Jane and ABC

Consultation: GST-free (unless the GP and ABC agree not to treat any supply made to ABC as GST-free)

The consultation is a GST-free supply to Jane.

Where a supply is also made to ABC, the supply will be GST-free as the underlying supply to Jane is GST-free.

As discussed in 2.1, where the supply is to ABC, the GP and ABC may choose not to treat it as GST-free.

12.2. The GP determines that Jane is fit to return to work, and completes a return to work report for ABC.

The GP issues an account to ABC for the consultation and completion of the report.

Return to work report: ABC

Return to work report: Taxable

The supply of the return to work report is taxable. It is taxable irrespective of whether a separate fee is specified in the account to ABC, or the fee is included in one combined fee for the supply of treatment.

The report is taxable because it is not integral to the appropriate treatment of Jane.

Where there is one combined fee for both the treatment and report preparation and neither dominates the supply of the other, the GP must apportion the fee between the GST-free and taxable parts of the supply. (Refer to Issue 2.3)