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  • Key messages

    Notional GST – Unimproved land – The ATO received a neutral evaluation on 15 April 2015 which supported the Commissioner’s position in relation to notional GST and unimproved land and the application of section 38-445 of the GST Act. A second neutral evaluation is being progressed focussing on the application of item 4 of the table in subsection 75-10(3) in respect of dams, fences and roads but it is not expected to be heard until early next year.

    Local Government class action – The ATO is aware of a potential class action by an advisor on behalf of more than 90 local Government bodies. It is understood that the proposed class action seeks to argue that a notional GST cannot be imposed on the state, and therefore local Government, as it is forbidden by section 114 of the Constitution. The class action is not expected to commence before November 2016.

    Penalties under section 2B of the TAA 1953 – Section 2B of the Taxation Administration Act 1953 (TAA) commenced operation on 25 February 2015 and does not allow the Commissioner to impose certain administrative penalties, general interest charges or shortfall interest charges under the TAA on entities with Crown immunity. MT 2011/1 Miscellaneous taxes: application of penalties and interest charges to the Commonwealth, States, Northern Territory and Australian Capital Territory and PS LA 2011/26 Administration of penalties and interest charges in relation to the notional liabilities of the States both have notes added to advise they are under review to consider implications for section 2B.

    Development lease arrangements with Government agencies and the application of GST ruling GSTR 2015/2 where the supply of land is GST-free – The ATO position adopted on the valuation of non-monetary consideration in GST Ruling GSTR 2015/2 - Goods and services tax: development leases with government agencies is itself based on the principles adopted in GST Ruling GSTR 2001/6 – Goods and Services tax: non-monetary consideration. The principles that are applied mean the things exchanged between the parties are of equal GST inclusive market value as explained at paragraph 69 of GSTR 2015/2 and where a GST-free supply is treated as consideration, this consideration has a GST inclusive market value with the GST component being ‘nil’.

    Third party reporting – Government grants and payments – The ATO provided an update on the new legislation for Government grants and payments which will commence on 1 July 2017. The first report will be due on 28 August 2018 for the financial year ending 30 June 2018. The new measures require Government entities at the federal, state, territory and local levels to report annually the total payments they make to a business for the provision of services. Additionally, Government entities at the federal, state and territory levels will need to report the total grants paid to entities with an ABN.

    Agenda items

    Disclaimer

    GST States/Territories Industry Partnership meeting, agendas, minutes and related papers are not binding on the Tax Office or any of the States or Territories referred to in these papers. While every effort is made to accurately record the views expressed, the wording necessarily represents a summary of statements of general position only, and care should be taken in interpreting those statements. These papers reflect the position at the date of release (unless otherwise noted) and readers should note that the position on any issue may subsequently change.

    1. ATO updates

    Unimproved land

    The ATO received a neutral evaluation on 15 April 2015 which supported the Commissioner’s position in relation to notional GST and unimproved land and the application of section 38-445.

    A second neutral evaluation involving notional GST and unimproved land is being progressed focussing on the application of item 4 of the table in subsection 75-10(3) in respect of dams, fences and roads. It is not expected to be heard until early next year with parties currently agreeing to the questions at issue.

    Meeting discussion

    The issues being raised in the second neutral evaluation were discussed with members. The second neutral evaluation does not involve the same issues raised in the first evaluation which included whether clearing of the land constituted an improvement. The second neutral evaluation’s primary focus is whether the existence of fences, dams and roads as at 1 July 2000 constitute improvements for the purposes of item 4 of the table in subsection 75-10(3) when the land is later subdivided for residential development. The evaluation is progressing but it is not anticipated to be heard until approximately April 2017.

    ATO advised it is having discussions with some Government Land Associations who have put forward a number of principles for ATO consideration.

    Local government class action

    The ATO is aware of a potential class action by an advisor on behalf of more than 90 local Government bodies. It is understood that the proposed class action seeks to argue that a notional GST cannot be imposed on the state, and therefore local Government, as it is forbidden by section 114 of the Constitution. The class action is not expected to commence before November 2016.

    Meeting discussion

    It was raised by a member whether the local Government bodies considered the provisions of state laws that exist for the payment of notional GST liabilities. ATO advised it was not known whether their argument takes into account the existence of these laws.

    Penalties under section 2B of the Taxation Administration Act 1953

    Section 2B of the Taxation Administration Act 1953 (TAA) commenced operation on 25 February 2015 and it states: ‘This Act binds the Crown in each of its capacities. However, it does not make the Crown liable to a pecuniary penalty or to be prosecuted for an offence.’

    Section 2B of the TAA does not allow the Commissioner to impose certain administrative penalties, general interest charges or shortfall interest charges where liability is imposed under the TAA on entities with Crown immunity from statute. MT 2011/1 Miscellaneous taxes: application of penalties and interest charges to the Commonwealth, States, Northern Territory and Australian Capital Territory and PS LA 2011/26 Administration of penalties and interest charges in relation to the notional liabilities of the States both have notes added to advise they are under review to consider implications for section 2B.

    We are currently engaged with the States and Territories in respect of identifying those entities with Crown immunity.

    Meeting discussion

    ATO advised that Section 2B only applies to penalties or interest charges where liability is imposed under the TAA and there was discussion with members on whether they can help identify which entities in their jurisdictions have Crown immunity.

    Entities with Crown immunity are those that:

    • have no legal personality separate from the executive government (such as departments, ministries and government schools)
    • were established by a specific statute which expressly states that the entity has Crown immunities (all States and Territories), represents the Crown (NSW or Victoria only) or is a NSW government agency
    • if none of the above points are satisfied, were established by a specific statute which confers a high degree of legal control to the Minister or the executive government, or
    • if none of the above points are satisfied, were established under general corporations or associations legislation and the entity’s constitution, articles of association, ownership or governing legislation indicate a very high degree of control by the Minister or the executive government.

    Members advised of some situations where identifying whether an entity has Crown immunity had complexities. Members also discussed the distinguishing facts which can be strong indicators of whether an entity has Crown immunity. For example, the ability of the Minister to direct the entity in the performance of its functions would indicate that the Minister has a high degree of control in relation to that entity.

    ATO advised that where an entity has Crown immunity, the Commissioner cannot impose certain administrative penalties or interest charges on that entity. State and Territory entities that do not have crown immunity (such as local Government entities) will continue to be liable for penalties and interest charges (subject to any other exemptions).

    Action item 05102016/1

    Do penalties apply where a non-Crown entity is grouped with a Crown entity and the shortfall of tax is attributable to the non-Crown member?

    Post meeting response

    Penalties apply where the shortfall of tax is attributable to an entity that does not have Crown immunity, regardless of the GST grouping arrangements.

    Action item 05102016/2

    Would the fact that a Minister is the sole shareholder of an entity be indicative of that entity having Crown immunity?  

    Post meeting response

    Many government-owned corporations (GOCs) have the Minister as the sole shareholder but would not have Crown immunity. This may be expressly provided for in any government-owned corporations legislation applying to the entity. For example, under subsection 5(1) of the Government Owned Corporations Act (NT), certain government-owned corporations or subsidiaries do not have Crown immunity. Paragraph 9(a) of the State-Owned Corporations Act 1989 (NSW) and paragraph 70(a) of the State Owned Enterprises Act 1992 (Vic) have a similar effect.

    In other cases, it is necessary to assess the level of control exercisable by the Minister or executive government by analysing the entity’s constitution or articles of association and any other governing legislation, for example, the entity will only have Crown immunity if there is a high degree of executive control.

    2. Development lease arrangements with Government

    Issue

    Development lease arrangements with Government agencies and the application of GST ruling GSTR 2015/2 where the supply of land is GST-free

    Background

    Goods and Services Tax Ruling GSTR 2015/2 deals with development lease arrangements with government agencies. The following paragraphs are contained in GSTR 2015/2:

    69. Where the parties to a development lease arrangement are dealing with each other at arm's length, the Commissioner considers that the things exchanged between the parties are of equal GST inclusive market value. Therefore, in the context of a development lease arrangement between a government agency and a developer, the parties can use a reasonable valuation method as agreed between them to determine the GST-inclusive market value of any non-monetary consideration for supplies arising in the context of a development lease arrangement.
    82. Because the land is supplied by the government agency in exchange for both the monetary payment and the development services, the GST inclusive market value needs to be apportioned to determine the price of the supply of development services made by the developer. The apportionment is made by deducting the amount of the monetary payment from the GST inclusive market value of the land supplied by the government agency.
    83. In turn, the consideration for the government agency's supply of the land is determined by adding together the amount of the monetary payment and the GST inclusive market value of the development services supplied by the developer.

    According to GSTR 2015/2 the GST-inclusive market value of the land supplied by the government to the developer would be the sum of the monetary payment and the GST-inclusive market value of the non-monetary payment where the non-monetary payment is the development services supplied by the developer. This may be represented by:

    V = M + D Where:

    V = valuation of land including GST

    M = monetary payment

    D = GST inclusive development services

    This may be acceptable where the land being supplied by the government is a taxable supply. However, it is noted that GSTR 2015/2 states at paragraph 3:

    3. This Ruling does not consider the application of:
    • Subdivision 38-N of the GST Act (grants of land by governments)
    • Division 81 of the GST Act (payment of taxes, fees and charges), or
    • Division 82 of the GST Act (supplies in return for rights to develop land).

    It has been suggested that, because GSTR 2015/2 does not relate to a supply of GST-free land, the above values for GST-free land would be:

    V = valuation of GST-free land

    M = monetary payment

    D = GST exclusive development services

    It is argued that GST should not be included in development services when it is not included in the supply of the land. The effect of this is that the value of the land is less than the sum of the monetary payment and the GST inclusive development services by the amount of GST included in the development services. The developer then invoices the government for this shortfall.

    The alternate view is that the GST-inclusive market value of the land supplied by government to the developer should still be the sum of the monetary payment and the GST-inclusive market value of the development services. The GST included in the supply of GST-free land would be nil as suggested at paragraph 130 of GSTR 2001/6.

    Furthermore, example 22 at paragraph 131 of GSTR 2001/6 demonstrates how consideration for a GST-free supply includes the GST inclusive value of the non-monetary supply being traded.

    Industry view/suggested treatment

    Some developers are of the view, based on GSTR 2015/2, that the value of GST-free land should not include GST included in development services.

    Technical references

    GSTR 2015/2 Goods and services tax: development lease arrangements

    GSTR 2001/6 Goods and services tax: non-monetary consideration

    ATO response

    The position adopted about the valuation of non-monetary consideration in GST Ruling GSTR 2015/2 - Goods and services tax: development leases with government agencies is itself based on the principles adopted in GST Ruling GSTR 2001/6 – Goods and Services tax: non-monetary consideration.

    Notwithstanding that GSTR 2015/2 does not consider the application of Subdivision 38-N, Divisions 81 and 82 of the GST Act, the comments about the valuation of non-monetary consideration as explained at paragraphs 69, 82 and 83 of this ruling would apply equally in the context of development lease arrangements where the land is supplied GST-free. The rationale for this can be found at paragraph 68 of GSTR 2015/2 and paragraph 21 of GSTR 2001/6.

    Paragraph 68 of GSTR 2015/2 states, among other things, that where the consideration for a supply is non-monetary, the GST inclusive market value (emphasis added) of that consideration is used to work out the price and value of that supply (under paragraph 9-75(1)(b) of the GST Act as referenced at footnote 16).

    Footnote 16 also states that the term GST inclusive market value is defined at section 195-1 of the GST Act. Under the definition, the term ‘GST inclusive market value’ in connection with a supply, means the market value of the consideration without any discount for any amount of GST or luxury car tax payable on the supply.

    As provided at paragraph 130 of GSTR 2001/6, the GST treatment of non-monetary consideration (when it is viewed as a supply itself) is not relevant to its status as consideration. Where consideration itself is a GST-free supply, this consideration has a GST inclusive value with the GST component being ‘nil’. A practical example is provided at paragraph 131 of GSTR 2001/6 (Example 22).

    Looking at a development lease situation where the consideration comprises both monetary and non-monetary components as discussed at paragraphs 80 to 83 of GSTR 2015/2, the consideration for a GST-free supply of land by the Government Agency would be:

    Monetary Payment + GST inclusive market value of the development services (see paragraphs 83 and 87 of GSTR 2015/2).

    Conversely, if we apply the principle that the things exchanged are of equal GST inclusive market value as explained at paragraph 69 of GSTR 2015/2, the GST inclusive value of the land (with the GST component being ‘nil’) less the monetary payment would be equal to the GST inclusive market value of the Developer’s services (see paragraph 82 of GSTR 2015/2).

    Meeting discussion

    The issues raised in the Development Lease arrangement were discussed including the practical example provided at paragraph 131 of GSTR 2001/6 (Example 22). One member commented the example was most relevant to this development lease issue as it involves a taxable supply in exchange for a GST-free supply. ATO advised that the GST-free supply, when treated as consideration, has a GST inclusive market value with the GST component being ‘nil’.

    Transitional issues for development lease arrangements entered into prior to the publication of GSTR 2015/2 were also discussed and, in particular, where such lease agreements provide for a ‘development fee amount plus GST’.

    Action item 05102016/3

    Would the ATO response in determining the GST inclusive amount be different in the situation where a legally binding development lease agreement entered into prior to publication of GSTR 2015/2 provides for ‘development fee amount plus GST’ or includes a gross-up clause for GST?

    Post meeting response

    No, the ATO response would not be different where a legally binding development agreement entered prior to the publication of GSTR 2015/2 provides for ‘development fee amount plus GST’ or includes a gross-up clause for GST. In line with the explanations provided at paragraph 69 of GSTR 2015/2, the Commissioner considers that the things exchanged between the parties to a development lease arrangement are of equal GST inclusive market value and the ATO’s position is based on the definition of ‘GST inclusive market value’ as explained at paragraph 128 of GSTR 2001/6. Under this definition, the GST inclusive market value of non-monetary consideration in connection with a supply means the market value of that consideration, without any discount for any amount of GST or luxury car tax payable on the supply. 

    In the above scenario, if the parties agree to use the ‘development fee amount’ to determine the GST inclusive market value of the non-monetary consideration exchanged for their respective supplies, the GST inclusive market value of the Developer ’s development services would be the total development fee inclusive of GST (say $11 million, i.e. $10 million plus GST of $1 million, as provided in the development agreement) and conversely the GST inclusive market value of the land supplied by the Government Agency would be $11 million. The GST treatment of the land is not relevant to its status as consideration (please refer to paragraphs 130 & 131 of GSTR 2001/6).

    3. Tax invoices

    Issue

    Date entitled to input tax credit when supplier’s GST registration is back-dated.

    Background

    A supplier makes supplies over a period of time. The supplier was not registered for GST when commencing to make supplies and did not charge GST. Sometime later the supplier commences issuing tax invoices with GST. A check of the ABR shows the supplier is not registered for GST. When contacted, the supplier advises they are required to be registered for GST and have applied for GST registration. Some weeks later the supplier submits another tax invoice and a check of the ABR shows the supplier is registered for GST and the registration date has been back-dated to prior to previous tax invoices.

    The recipient of a supply is entitled to input tax credits for any creditable acquisition they make. However, an acquisition needs to be a taxable supply by the supplier to be a creditable acquisition to the recipient. To be a taxable supply the supplier needs to be registered, or required to be registered. It follows that, although a supplier is not registered for GST, they may be required to be registered and should, therefore, be required to issue tax invoices although not registered on the ABR. The recipient of the supply should be entitled to an input tax credit when the tax invoice is issued notwithstanding that the supplier is not registered for GST on the ABR at that point in time.

    ATO response

    In the above scenario the recipient of the supply attributes the input tax credits according to their accounting basis in the tax period in which they hold a tax invoice for the supply.

    It should however be noted that since it is the recipient making the creditable acquisition, the onus is on them to ensure that the supply made to them is taxable. Where the supplier is not shown as registered for GST on the ABR, we would expect the recipient to take reasonable steps to satisfy themselves that the supplier is in fact required to be registered. For example, in the situation depicted above, it would be reasonable for the recipient to request a copy of the supplier’s GST registration application.

    4. Lump sum payments section 56 of Return to Work Act 2014 (SA)

    Issue

    Clarification of the application of draft Taxation Determination TD 2016/D1 to lump sum payments for economic loss under section 56 of the Return to Work Act 2014 (SA)

    Background

    The ATO published draft Taxation Determination TD 2016/D1 Income tax: is a redemption payment received by a worker under the Return to Work Act 2014 (SA) assessable income of the worker on 10 August 2016. According to the draft determination lump sums paid to workers to redeem ReturnToWorkSA’s (RTWSA) liability to pay weekly payments and/or supplementary income support under sections 39, 40 and 41 of the Return to Work Act 2014 (SA) would be treated as assessable income.

    A redemption payment covered by the draft determination is ordinary income of the worker and is therefore assessable under section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997).

    For the purposes of this draft Determination, a payment is a redemption payment to the extent that:

    • it is made pursuant to subsection 53(1) or subsection 54(3) of the Return to Work Act 2014 (SA)
    • it is made to redeem a liability to make weekly payments under sections 39, 40 or 41, and
    • it is not an employment termination payment for the purposes of subsection 82-130(1) of the ITAA 1997.

    The determination addresses taxation treatment for subsections 53(1) and 54(3) but clarification is sought on its application to section 56 of the Return to Work Act 2014 (SA).

    Questions

    1. Confirmation required as to whether a lump sum under section 56 of the Return to Work Act 2014 (SA) for economic loss would be considered assessable? Paragraph 23 of TD 2016/D1 indicates that such payments would not be considered assessable.
    2. Confirmation required that lump sums paid under the Workers Rehabilitation and Compensation Act 1986 (SA) would not be treated as assessable income.

    ATO response

    Question 1 – Lump sum payments under section 56 of the Return to Work Act 2014 (SA) relates to economic loss due to a permanent impairment suffered by a worker. Where the payments made are in the nature of compensation for deprivation or impairment of earning capacity, such payments are not assessable income and are exempt from CGT under section 118-37 of the Income Tax Assessment Act 1997 (ITAA 1997). The draft determination is limited to payments under sections 53 and 54 of the Return to Work Act 2014 (SA).

    Question 2 – Lump sum payments paid under the Workers Rehabilitation and Compensation Act 1986 (SA) and which are referred to in paragraph 6 of TD 93/3 Income tax: is a payment, being a partial commutation of weekly compensation payments, assessable income are not considered by draft TD 2016/1 and such payments will continue to be treated as non assessable amounts.

    5. Appropriations

    Issue

    Who does the onus fall upon to prove that a payment is an appropriation, and does not therefore attract GST?

    Background

    Department A provides data extracts to Department B as part of their core business, and Department A invoices Department B, GST inclusive. This is consistent with invoicing to other government departments for similar data extracts, and prior invoicing arrangements with Department B.

    Department B has contacted Department A to query the GST, and indicated that the invoice should be exclusive of GST on the basis that the payment is covered by an appropriation.

    Department A has included GST on the basis that the service provided (provision of data extracts) does not meet the second of the following criteria and, therefore should be considered a taxable supply and subject to GST:

    • By a government related entity to another government related entity, and
    • The payment is covered by an appropriation under an Australian law, and
    • The payment is calculated on a cost recovery basis. i.e. the payment does not exceed the supplier’s  anticipated or actual costs of making those supplies.

    Department A has requested Department B provide documentation to show that the payment is an appropriation but Department B has not provided documentation to support that it is covered by an appropriation.

    ATO response

    Subsection 9-17(3) of the GST Act provides that a payment is not consideration for a supply if:

    • a payment is made by a government related entity to another government related entity for making a supply; and
    • the payment by the payer is covered by an Australian appropriation Law or is made under a specified intergovernmental health reform agreement; and
    • the payment satisfies the non-commercial test.

    For a supplier to characterise a supply as not being subject to GST on the basis of subsection 9-17(3) of the GST Act, the supplier should have sufficient evidence to support that characterisation. In this situation, the recipient of the supply is asserting that the payment is covered by an appropriation. For the supplier to be satisfied that this limb of subsection 9-17(3) of the GST Act is satisfied, the recipient of the supply should provide evidence to support their assertion. If such evidence is not forthcoming and the supplier cannot be certain that the limb is satisfied, the supplier should not treat subsection 9-17(3) of the GST Act as being satisfied until such time as appropriate evidence is available.

    6. Third party reporting - Government grants and payments

    ATO provided an update on the new legislation for Government grants and payments which will commence on 1 July 2017. The first report will be due on 28 August 2018 for the financial year ending 30 June 2018.

    Meeting discussion

    ATO provided members with information on taxable payments reporting for Government entities including how to lodge the annual report.

    Government entities at the federal, state, territory and local levels will need to report annually the total payments they make to a business for services as from 1 July 2017.

    Additionally, Government entities at the federal, state and territory levels will need to report the total grants paid to entities with an ABN. Some government entities, such as hospitals, schools and libraries, are exempt through legislative instruments and are not required to report.

    The information reported to the ATO may be used for pre-filling purposes to make it easier for individual businesses to lodge tax returns. It will also be used in the ATO data matching program to identify businesses that have:

    • not lodged tax returns
    • omitted income from tax returns that have been lodged
    • not met their GST obligations.

    The Taxable payments annual report will be due by 28 August each year. Government entities will need to update their systems to collect the required information from 1 July 2017. Reports will need to be submitted electronically in a format that meets ATO specifications. These specifications can be downloaded from the ATO at softwaredevelopers.ato.gov.au/tparGovExternal Link.

    ATO advised that each jurisdiction will need to determine which of their government entities will need to report and what payment transactions are required to be reported based on their consideration of the law, and the legislative instruments which exempt certain entities and payments, as well as information published on the ATO website at ato.gov.au/tparGov.

    If members still have questions after referring to the ATO website, they should contact the ATO for further information by:

    Action item 05102016/4

    An electronic copy of the ATO presentation was provided to members post meeting, including the details of two ATO Webinar sessions in October and November 2016.

    7. GST technical update

    Discussion of recent legislative changes, judicial decisions and published ATO rulings and guidance with GST impacts for government entities.

    Meeting discussion

    There was discussion in relation to Law Companion Guideline LCG 2016/1 and the Practical Compliance Guidelines PCG 2016/1 and PCG 2016/7. The reverse charging and the Tax and Superannuation Laws Amendment (2016 Measures No. 1) Act 2016 which commenced on 1 October 2016 was also discussed.

    Action item 05102016/5

    Does a reverse charging arrangement due to changes under the Tax and Superannuation Laws Amendment (2016 Measures No. 1) Act 2016 require the supplier and the recipient to have entered into an agreement?

    Post meeting response

    No. In broad terms, Division 84 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act)applies to supplies of anything other than goods or real property that are not connected with the indirect tax zone (ITZ) and that are acquired:

    • by a recipient that is required or required to be registered;
    • solely or partly for the purpose of an enterprise carried on by the recipient in the ITZ; and
    • not solely for a creditable purpose.

    Where Division 84 applies to such a supply, the supply becomes a taxable supply and any GST on the supply is payable by the recipient.

    Where a supply is disconnected because it is made to an entity that is an Australian-based business recipient of the supply (under the Tax and Superannuation Laws Amendment (2016 Measures No. 1) Act 2016), that entity is responsible for determining if they have a GST liability in relation to the supply under the reverse charge rules in Division 84. There is no requirement that the supplier and the recipient have to enter into an agreement.

    Although a particular supply that is excluded from the connected with the ITZ rules as a result of these amendments may be subject to Division 84, it is not necessarily the case that Division 84 requires that the supply be reverse charged. If the acquisition is fully creditable in the recipient’s hands, Division 84 does not apply. This reflects that there is no need to collect GST through a reverse charge where the GST revenue from the reverse charge is fully offset by an equivalent ITC claimed by the recipient.

    It should be noted that Division 83 also contains reverse charge rules that may apply to a supply between a non-resident supplier and a recipient that is registered or required to be registered. These rules apply to taxable supplies if the supplier and recipient agree that the GST on the supply should be payable by the recipient.

    8. General business

    8.1 Removing irritants and better support

    We would like to continue to work with the States and Territories to identify irritants for government agencies and receive suggestions on how the ATO can better support the government sector.

    8.2 Future GST impacts for States and Territories

    We would like the States and Territories to consider the following questions for discussion at the meeting.

    • What issues from a GST perspective do the States and Territories anticipate in the future?
    • How will the States and Territories be equipped to respond to these impacts?
    • What challenges to sustainability of compliance do the States and Territories face over the next few years?
    • How effective (easier, contemporary, cost effective, more tailored) is the design of existing ATO systems for the administration of GST?
    • How can any deficiencies be shaped to become more effective?

    Meeting discussion

    No issues were raised by members.

    8.3 GST STIP minutes

    The minutes from the last GST STIP meeting held on 27 April 2016 have been published on the ATO website and can be accessed via this link – GST States and Territories Industry Partnership minutes 27 April 2016.

      Last modified: 16 Mar 2017QC 51521