Goods and Services Tax Advice


Goods and services tax: Is B's payment to A consideration for A's supply to B where, under an agreement between A and B:

A licenses intellectual property to B (who sublicenses it to C) and;
the amount B pays A is calculated by reference to the extent of B's supply to C?

  • Please note that the PDF version is the authorised version of this ruling.
    This document has changed over time. View its history.

Notice of Withdrawal

Goods and Services Tax Advice GSTA TPP 054 is withdrawn with effect from today.

1. GSTA TPP 054 considered a particular transaction and the associated supplies and the consideration for the supply. The advice explained that a supply is made for consideration when there is a sufficient nexus between that supply and the consideration provided by the recipient.

2. GSTA TPP 054 is withdrawn because the concepts of consideration and supplies considered in the advice are explained in existing public rulings.

3. These concepts are explained in Goods and Services Tax Ruling GSTR 2006/9 Goods and services tax ruling: supplies and Goods and Services Tax Ruling GSTR 2001/6 Goods and services tax ruling: non-monetary consideration.

Commissioner of Taxation
2 July 2014


You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Not previously issued as a draft


ATO references:
NO 05/3095

ISSN: 1833-0053

Related Rulings/Determinations:

TR 2006/10
GSTR 2001/4
GSTR 2001/6

Subject References:
in connection with

Legislative References:
TAA 1953 Sch 1 Div 358

GSTA TPP 054W history
  Date: Version: Change:
  14 June 2005 Original ruling  
  31 October 2012 Consolidated ruling Addendum
You are here 2 July 2014 Withdrawn