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Notional GST dispute resolution for government entities

How to lodge a notional GST dispute resolution request as a government entity.

Last updated 26 June 2026

Overview

The notional GST dispute resolution process is a process for resolving disputes between a government entity and the ATO in respect of a notional GST issue.

This process does not apply to other disputes, even if the dispute is with a government entity.

What notional GST is

Notional GST refers to certain GST amounts which government entities are not legally required to pay, but which the Commonwealth, the states and the territories have agreed their government entities will pay. The table below outlines whether the amount is legal GST or notional GST.

Table: Legal and notional GST

Jurisdiction

Legal GST

Notional GST

Commonwealth
  • None
  • All GST
  • All GST credits

States (including local government in each state)
  • GST (other than GST on property)
  • All GST credits
  • GST on property

Australian Capital Territory
  • GST (other than GST on real property supplied on behalf of the Commonwealth)
  • All GST credits (other than GST credits on acquisitions made on behalf of the Commonwealth)
  • GST on real property supplied on behalf of the Commonwealth
  • GST credits on acquisitions made on behalf of the Commonwealth

Northern Territory (including local government in the Northern Territory)
  • All GST
  • All GST credits
  • None

How to dispute an ATO position

Due to the nature of notional GST, the usual review options of objection and appeal may not be appropriate. The most appropriate pathway to resolve a notional GST matter will depend on the issue in dispute.

Notional GST disputes can arise:

  • during an ATO engagement or assurance activity
  • as a result of an ATO private ruling.

If you don't agree with:

  • an ATO position during your engagement or assurance activity, you can explore alternate dispute resolution (ADR) options if both parties agree
  • the outcome of an ATO engagement or assurance activity, including where an assessment has been made, you can seek an ATO internal review – you can also explore ADR options as part of this review if both parties agree
  • the outcome of a private ruling, you can seek review by lodging an objection.

To seek an ATO internal review, contact us through online services using secure mail. If you cannot access online services, you can email us at NotionalGSTDisputeProcess@ato.gov.au. We will discuss the internal review options best suited to your circumstances with you.

For more details on notional GST dispute resolution options, see the notional GST dispute resolution process.



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