Edited version of private ruling

Authorisation Number: 1011556470124

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Ruling

Subject: GST and reduced input tax credits and mortgagee in possession

Question 1

Does an entity have an entitlement to reduced input tax credits (RITC) under subregulation 70-5.02(2) of the A New Tax System (Goods and Services Tax) Regulations 1999 (GST Regulations) on the acquisition of legal services for the preparation and certification of loan documentation, registration of mortgage security and title searches?

Answer

Yes, an entity has an entitlement to RITC under subregulation 70-5.02(2) of the GST Regulations on acquisition of legal services for preparation and certification of loan documentation, registration of mortgage security and title searches.

Question 2

Does an entity have an entitlement to a RITC under subregulation 70-5.02(2) of the GST Regulations on acquisition of services associated with enforcing a borrower's obligations under the terms of his or her loan agreement?

Answer

Yes, an entity has an entitlement to RITC under subregulation 70-5.02(2) of the GST Regulations on acquisition of services associated with enforcing a borrower's obligations under the terms of their loan agreement.

Issue 2

Is an entity entitled to any input tax credits under section 11-20 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) or any RITC under subregulation 70-5.02(2) of the GST Regulations when the entity incurs property-related expenses when acting as agent for borrowers to repair and maintain mortgaged property?

Answer

Yes, an entity is entitled to claim full input tax credits under section 11-20 of the GST Act when the entity incurs property-related expenses when acting as agent for borrowers to repair and maintain mortgaged property.

Issue 3

Is an entity entitled to claim input tax credits under section 11-20 of the GST Act on expenses incurred when the entity takes possession of a property (that is, the entity becomes mortgagee in possession) for sale or to renovate/develop the property for resale? In this question it is assumed that the supply of the property in question is a taxable supply.

Answer

Yes, an entity is entitled to claim full input tax credits under section 11-20 of the GST Act on expenses incurred when the entity takes possession of a property (that is, the entity becomes mortgagee in possession) for sale or to renovate / develop the property for resale and the expenses do not relate to supplies that would be input taxed or have a private or domestic nature.

Issue 4

Does Division 105 of the GST Act still apply when an entity takes possession of a property (that is, becomes mortgagee in possession) where the property is owned by a third party (rather than the borrower)?

Answer

Yes, Division 105 of the GST Act is applicable when an entity takes possession of a property (i.e. becomes mortgagee in possession) and the property is owned by the guarantor to the loan agreement.

Relevant facts and circumstances

This entity is a financial services group that advances loans to borrowers.

The loans advanced to borrowers are secured by registered mortgages over real property.

Upon settling, discharging or varying a loan, you incur legal expenses for the preparation and certification of documents, registration of mortgage security, title searches and other fees and expenses.

All of the above fees include GST.

This entity has indicated it is a financial supply provider.

This entity on-charges all legal and property expenses (inclusive of GST) to the borrower.

This entity on-charges expenses associated with enforcing a borrower's obligations to this entity (the lender).

This entity provided a copy of a loan agreement.

Occasionally, some of this entity's borrowers default on their obligations.

In these cases, this entity commences enforcement action and incurs the following expenses:

· legal fees

· out-of-pocket expenses

· court filing fees

· process server fees;

· investigator fees 

· mediation fees

In all cases, the action is taken to recover a specific amount (debt) owed to this entity.

In certain circumstances this entity incurs expenses relating to mortgaged properties. This entity does this to protect the value of the property when the borrower does not maintain the mortgaged property in good order.

These properties can be either commercial properties or residential properties.

These expenses are incurred after a default event has occurred, but before this entity has taken possession of the property for sale.

This entity may also not need to take possession of the property as the loan may be returned to good order before this is necessary.

After taking possession of the properties, this entity may choose to either rent them out or sell them.

The costs are incurred by this entity as agent for the borrower.

Under the terms of its loan agreement, the mortgagor appoints this entity as the mortgagor's attorney after a default event occurs. This power allows this entity to do anything the mortgagor itself could do. Anything this entity does in this capacity it does as agent for the mortgagor, not as principal in its own right.

Sometimes this entity lends money to a borrower for business-related purposes and not to acquire a property. The property is owned by the guarantor, where the guarantor puts up property as security. Therefore, if property expenses are incurred they are incurred on the property of the guarantor.

A guarantor who owns the property that is mortgaged to the entity is obligated to repay the loan on default in terms of the guarantee obligations. If the loan is not repaid then this entity exercises its right to recover over the mortgaged property in terms of the mortgage loan agreement.

This entity also wishes to draft agreements with either a borrower or guarantor depending on the structure of the loan. The agreement, commencing from the start of the loan will only be between this entity and either borrower or guarantor. This agreement would cover GST on expenses related to the property incurred by this entity on behalf of either the borrower or guarantor It will not be a tripartite agreement.

Issue 1 - Question 1

Reduced credit acquisitions

Reduced credit acquisitions are certain types of purchases listed in the GST Regulations. An entity can claim a reduced GST credit when it uses them to make financial supplies.

This means that even though an entity exceeds the financial acquisition threshold, it may still be entitled to reduced credit acquisitions on various fees for the loans it provides.

Item 14 of subregulation 70-5.02(2) of the GST Regulations (item 14) allows a reduced input tax credit for certain loan application, management and processing services acquired in the course of conducting loan transactions.

Goods and Services Tax Ruling: GSTR 2004/1: Goods and services tax: reduced credit acquisitions, sets out the provisions of item 14:

Item 14

The following loan application, management and processing services:

(a) loan origination and brokerage;

(b) settlement and discharge of loans, including document preparation;

(c) registration of loan documents;

(d) credit reference assessment and credit scoring assessment;

(e) valuations;

(f) property title searches;

(g) registration and certification of titles;

(h) mortgage variations, including name changes;

(i) adding and deleting caveats to titles

This entity is a financial supply provider that acquires services for the preparation of loan documents in order to settle, vary and discharge loans. These services include certification of transaction documents but do not include preparation of letters of advice or legal opinions.

Paragraph 371 of GSTR 2004/1 indicates 'Item 14 contains an exhaustive list of loan application, management and processing services and …there is no requirement in item 14 that the services, referred to in items 14(a) to 14(i), must be provided by a financial supply facilitator. Further paragraph 374 of GSTR 2004/1 referred to in the facts of this case indicates 'a loan originator who lends funds in its own right, (often referred to as a non-bank lender) is a financial supply provider. As regulation 70-5.02 relates to acquisitions made by financial supply providers, loan origination in the context of item 14(a) refers to a service of initiating loans on behalf of the lender.'

Legal fees for the preparation and certification of loan documentation

Item 14(b) - settlement and discharge of loans, including document preparation

384. In the context of item 14(b), settlement of loans is the making available of funds at the commencement of the loan. Discharge of loans involves a number of administrative activities, including handing over the certificate of title of a mortgaged property to the borrower, and preparing and issuing a document to the borrower certifying that the loan has been discharged.

385. The acquisition of document preparation services, otherwise than as a service of managing or processing loans, is not a reduced credit acquisition to which this item applies. Document preparation, in this context, refers to preparation of documents as part of either the settlement of loans or the discharge of loans, and does not extend to preparation of letters of advice or legal opinions.

As this entity is a financial supply provider, it is agreed that loan documentation expenses fall under item 14(b) of subregulation 70-5.02(2) of the GST Regulations and is supported by paragraph 385 of GSTR 2004/1.

This entity is therefore able to claim a reduced input tax credit on its expenses for certification of transaction documents under item 14 in the table in subregulation 70-5.02(2) of the GST Regulations.

Registration of mortgage security

Item 14(c) - registration of loan documents

386. Where a loan is to be secured by a mortgage and the land is held under Torrens title, the mortgage is registered on the certificate of title.

387. In the context of item 14(c), the registration of loan documents includes the registration of any mortgages or encumbrances on the title of property which is held at the relevant state Registry or Land Titles Office or equivalent.

This entity's loans are secured by registered mortgages over real property and the entity is a financial supply provider. We agree that registration of mortgage security expenses fall under item 14(c) of subregulation 70-5.02(2) of the GST Regulations and is supported by paragraph 387 of GSTR 2004/1.

This entity is therefore able to claim a reduced input tax credit in relation to the GST included in the cost of registering mortgages on the title of mortgaged property under Item 14(c) in the table in subregulation 70-5.02(2) of the GST Regulations.

Title searches

Item 14(f) - property title searches

399.….

400. A property title search normally involves an examination of the relevant folios, dealings, instruments and other records, to confirm title, and to determine whether there are any encumbrances or other qualifications attaching to it. Such records are held by the relevant state Registry or Land Titles Office.

401. An acquisition of the services of a solicitor or other service provider to conduct property title searches is a reduced credit acquisition under item 14(f) where the services are acquired in respect of property used as security for a loan.

In order to settle this entity's loans it is necessary for property title searches to be carried out. These searches confirm the title and any encumbrances or other qualifications attached to title.

We agree that the expenses of these title searches falls under item 14(f) of subregulation 70-5.02(2) of the GST Regulations and is supported by paragraphs 400 to 401 of GSTR 2004/1.

The amount of a reduced input tax credit is 75% of the GST included in the fees and expenses this entity incurs on preparation and certification of loan documentation and registration of mortgage security and title searches.

Issue 1 Question 2

Debt collection services

Item 17 of subregulation 70-5.02(2) of the GST Regulations (item 17) allows a reduced input tax credit for certain specified debt collection services. GSTR 2004/1 sets out the provisions of item 17:

Item 17

The following debt collection services:

(a) debt recovery;

(b) litigation;

(c) lodgment of documents;

(d) by financial supply facilitator, managing the recovery of sums due by borrowers

In certain situations this entity's borrowers default on their loan obligations. As a result, this entity commences enforcement action and incurs a variety of expenses.

This entity is a financial supply provider that acquires a range of debt collection services including debt recovery, litigation and lodgment of documents.

This entity's legal fees arise from several possible actions taken by this entity to recover a specific debt owed to it. These actions include order for possession; defending an application by the borrower or mortgagor to prevent the entity from selling a mortgaged property; and judgement debt leading to a bankruptcy.

Paragraph 425 of GSTR 2004/1 indicates that:

425. Item 17 provides an exhaustive list of debt collection services, the acquisition of which may be reduced credit acquisitions under that item. Debt collection in this context, refers to taking action to recover overdue debts. The acquisition of services not mentioned in items 17(a) to 17(d) is not a reduced credit acquisition unless it is covered by another item in subregulation 70-5.02(2).

Further paragraph 426 of GSTR 2004/1 also indicates that 'Before the acquisition of a particular service can be a reduced credit acquisition mentioned in item 17, the service must do more than merely relate, or contribute, to the service mentioned.'

Legal fees, including barristers fees (collectively, 'legal fees') and Out-of-pocket expenses associated with the above legal fees;

Item 17(b) - litigation

435. Acquisitions of litigation services that make up the litigation process for the purposes of debt collection, are reduced credit acquisitions.

436. It is not enough that an acquisition relates to litigation in some way, or that the activity is preliminary to, or follows from, litigation. Specifically, the litigation must be a debt collection service, that is, it must be directed towards collection of a debt. Litigation, in this context, is 'the conduct of legal proceedings by parties before a court.

The legal fees and associated expenses this entity incurs are to ensure the collection of specific debts.

Therefore, in this situation, legal fees and associated expenses to barristers fall under item 17(b) of subregulation 70-5.02(2) of the GST Regulations supported by paragraphs 435-436 of GSTR 2004/1.

This entity is therefore able to claim a reduced input tax credit in relation to the GST included in the acquisition of legal services and out of pocket disbursements under Item 17(b) in the table in subregulation 70-5.02(2) of the GST Regulations.

Court Filing Fees and Process Server Fees

437. Examples of activities that make up the litigation process include, the preparation and filing of claims for a debt in a court, serving of summonses (for example, by a bailiff or mercantile agent), and the litigation services of solicitors and barristers in conducting legal proceedings (for example, court appearances).

From the facts provided to us we agree that these activities form part of the litigation process and should fall under item 17(b) of subregulation 70- 5.02(2) of the GST Regulations and is supported by paragraph 437 of GSTR 2004/1.

This entity is therefore able to claim a reduced input tax credit in relation to the GST included in its acquisitions of preparation services of claims for debts and court filing fees as well as process server fees under Item 17(b) in the table in subregulation 70-5.02(2) of the GST Regulations.

Investigator fees

427. Although the relevant service need not be performed by an entity that specialises in debt collection, the service must be performed for the purpose of collecting a debt before it can be a reduced credit acquisition under item 17. It is not enough for the service to be litigation or lodgment of documents. The litigation or lodgment must be directly connected to the collection of a debt. This is because each of the things mentioned is considered within the context of a debt collection service.

428. Any one debt collection service might fall within more than one of items 17(a) to 17(d).

This entity has indicated that the services of an investigator are required to gather evidence for the successful recovery of monies owed to it and to compile evidence required for debt-recovery litigation.

On this basis, investigator fees may fall under Item 17(a) of subregulation 70- 5.02(2) of the GST Regulations when they are incurred for gathering evidence relating to debt recovery. Paragraph 427 of GSTR 2004/1 provides support for this view.

Alternatively, investigator fees may also fall under Item 17(b) of subregulation 70- 5.02(2) of the GST Regulations for evidence relating to debt recovery litigation. Paragraph 435 of GSTR 2004/1 provides support for this view.

Indeed paragraph 428 of GSTR 2004/1 acknowledges 'any one debt collection service might fall within more than one of items 17(a) to 17(d)'.

This entity is therefore able to claim a reduced input tax credit in relation to the GST included in its acquisition of investigator services for evidence integral to debt recovery and evidence required for debt-recovery litigation under either Item 17(a) or 17(b) in the table in subregulation 70-5.02(2) of the GST Regulations.

Mediation fees

429. The acquisition of services that are intrinsic or integral to recovering a debt is a reduced credit acquisition. The services must more than merely relate to debt recovery in some way. Where a service directed towards recovery of a debt is acquired, the acquisition is a reduced credit acquisition under item 17(a). Where only some of the activities that lead to the recovery of debt are acquired, the entity does not acquire debt recovery services for the purposes of this item. However, the acquisition of these services may be reduced credit acquisitions under another item.

430……

Example 50 - debt recovery services

431. Chameleon Limited, a wholesaler, engages Dumfries and Spline, a firm of solicitors, to write a letter of demand to one of the retailers it supplies, requesting immediate payment of an overdue account. The services of the solicitors are directed towards the recovery of a debt. The acquisition of the services is a reduced credit acquisition under item 17(a)

Mediation fees are incurred when this entity enters into mediation with a borrower in an attempt to recover a debt.

This entity has indicated that mediation is a service directed towards debt recovery.

We agree that mediation fees fall within Item 17(a) of subregulation 70- 5.02(2) of the GST Regulations. Paragraph 429 of GSTR 2004/1 provides support for this view.

This entity is therefore able to claim a reduced input tax credit in relation to the GST included in its acquisition of mediation services directed towards debt recovery under Item 17(a) in the table in subregulation 70-5.02(2) of the GST Regulations.

Enforcing a judgement

438. Activities carried out to enforce a judgment are not part of the litigation process, but are debt recovery services. Enforcement warrants (for redirection of earnings or seizure and sale of chattels) may be reduced credit acquisitions under item 17(c) (lodgment of documents). Litigation that goes to establishing the existence of a debt is not directed towards the collection of a debt.

Item 17(c) - lodgment of documents

439. There are two broad classes of document lodgments commonly undertaken as debt collection services. One is the lodgment of documents at court to start legal action. This class also includes all subsequent documents, such as enforcement warrants. The second class includes documents lodged at titles offices. These documents are to register writs on land. Where these services are carried out as part of a debt collection service, the acquisition of those services is a reduced credit acquisition. For example, where a creditor engages a solicitor to lodge documents at the relevant titles office, the acquisition of the solicitor's service is a reduced credit acquisition if the lodgment of documents is directly connected to the collection of a debt.

The cost this entity incurs in enforcing a judgement is considered an acquisition of services intrinsic or integral to debt recovery. This is supported by paragraphs 438 and 439 of GSTR 2004/1.

On this basis the costs this entity incurs in enforcing a judgement are reduced credit acquisitions in accordance with Item 17(c) in the table in subregulation 70-5.02 (2) of the GST Regulations.

Issue 2

Subdivision 153-B of the GST Act applies to entities that are registered or required to be registered for GST and that make a taxable supply or creditable acquisition through an agent.

Specifically, section 153-60 of the GST Act looks at the effect of these arrangements on acquisitions.

In this entity's situation, it will make a taxable supply when it supplies the property of the borrower, if the debtor made the supply it would have been a taxable supply upon this entity taking possession of the property as provided under Division 105 of the GST Act.

However this 'default event' has occurred at a point in time prior to possession taking place.

Paragraph 11 of Goods and Services Tax Ruling: GSTR 2000/37: Goods and services tax: agency relationships and the application of the law indicates that 'for commercial law purposes, an agent is a person who is authorised, either expressly or impliedly, by a principal to act for that principal so as to create or affect legal relations between the principal and third parties.'

On this basis, we agree that because this entity is acting as agent for the borrower it can enter into agreements under section 153-50 of the GST Act.

Paragraphs 74 and 75 of GSTR 2000/37 explain how input tax credits can be claimed by the agent as principal in a section 153-50 agency arrangement:

Principals and agents as separate suppliers and/or acquirers under Subdivision 153-B

74. Section 153-50 provides that entities may enter into an arrangement under which an agent is treated as a separate supplier and/or acquirer. That is, the agent is treated as a principal in its own right. …….

74A. Even though supplies that are not taxable supplies may be included in a Subdivision 153-B arrangement, section 153-55, which is about the effect of these arrangements on supplies, only applies to the taxable supplies covered by the arrangement. Similarly, section 153-60, which is about the effect of these arrangements on acquisitions, only applies to the creditable acquisitions covered by the arrangement. For supplies other than taxable supplies and acquisitions other than creditable acquisitions, the parties account for them as being from principal to principal for GST purposes. As sections 153-55 and 153-60 do not apply in this circumstance, the parties need to account for those supplies and/or acquisitions in the arrangement separately from the supply of agency services. …..

Using paragraph 74A of GSTR 2000/37 as support, we agree that this entity is acting as principal for GST purposes for the borrower and can claim input tax credits for certain acquisitions.

Therefore, the normal rules contained within Division 11 of the GST Act would apply to an acquisition made by this entity on behalf of the borrower at the point in time the default event occurs under the loan agreement.

We have previously referred to section 11-20 of the GST Act which indicates this entity will be entitled to an input tax credit for any creditable acquisitions it makes.

In these circumstances this entity will be eligible for a full input tax credit under section 11-20 of the GST Act for the GST incurred on these acquisitions provided they do not relate to supplies that would be input taxed or have a private or domestic nature.

This entity also asks whether it is entitled to any RITC under section 70-5 of the GST Act when it incurs property-related expenses acting as agent for borrowers to repair and maintain mortgaged property.

As this entity is entitled to claim a full input tax credit under section 11-20 of the GST Act this part of the question has not been addressed.

Issue 3

This entity incurs various expenses as mortgagee in possession and for some properties it has GST inclusive expenses as mortgagee in possession when it renovates or develops the property for a greater chance of debt recovery.

In this situation the entity takes possession of the property (not legal ownership). In these circumstances the entity will be deemed to be the supplier of the property.

The entity adds these GST inclusive expenses to the amount owed by the borrower and recovers them from the proceeds emanating from the sale of the property.

Division 105 of the GST Act provides that where certain conditions are met, a lender will be liable for GST on supplies of a borrower's property where the supply is in satisfaction of a debt owed to the lender.

Please note that this relates to circumstances where the ownership of the property does not transfer to the mortgagee.

Section 105-5 of the GST Act states that:

(1)

You make a taxable supply if:

(a) You supply the property of another entity (the debtor) to a third entity in or towards the satisfaction of a debt that the debtor owes to you; and

(b) had the debtor made the supply, the supply would be a taxable supply.

(2)

It does not matter whether:

(a) you made the supply in the course or furtherance of an enterprise that you carry on; or

(b) you are registered, or required to be registered.

(3)

However the supply is not a taxable supply if:

(a) the debtor has given you a written notice stating that the supply would not be a taxable supply if the debtor were to make it and stating fully the reasons why the supply would not be taxable supply; or

(b) if you cannot obtain such a notice you believe on the basis of reasonable information that the supply would not be a taxable supply if the debtor were to make it.

In this entity's situation, it makes a taxable supply when it supplies the property of the borrower if the debtor made the supply it would have been a taxable supply.

However Division 105 of the GST Act does not address the entitlement of lender to input tax credits for the GST paid in relation to the acquisition of goods and/or services in the course of making the supply of the borrower's property in satisfaction of a debt.

Therefore, the normal rules contained within Division 11 of the GST Act would apply to an acquisition made by the lender when realising the property of the borrower.

Section 11-20 of the GST Act provides you will be entitled to an input tax credit for any creditable acquisitions you make.

Section 11-5 of the GST Act provides the requirements that need to be satisfied in order for an acquisition to be a creditable acquisition. The requirements are:

(a) you acquire anything solely or partly for a creditable purpose; and

(b) the supply of a thing to you is a taxable supply; and

(c) you provide, or are liable to provide, consideration for the supply; and

(d) you are registered, or required to be registered.

With respect to the creditable purpose test referred to in paragraph (a) above, subsection 11-15(1) of the GST Act provides that an entity acquires a thing for a creditable purpose to the extent that it is acquired in carrying on an enterprise.

Further subsection 11-15(2) of the GST Act states that an entity does not acquire a thing for a creditable purpose to the extent that:

(a) the acquisition relates to making supplies that would be input taxed; or

(b) the acquisition is of a private or domestic nature.

Where section 105-5 of the GST Act applies and this entity is making a taxable supply of the borrower's property, the acquisitions it refers to in the facts will be for a creditable purpose. These services are directly referable to the making of a taxable supply in the course or furtherance of an enterprise that it carries on.

In these circumstances the entity will be eligible for a full input tax credit under section 11-20 of the GST Act for the GST incurred on these acquisitions provided the entity does not relate to supplies that would be input taxed or have a private or domestic nature.

In accordance with subsection 70-5(1A) of the GST Act, these acquisitions would not be a reduced credit acquisition.

Input taxed supplies

Although this entity asked us to assume the property in question is a taxable supply for this question, it is noted in the facts that this entity incurs expenses relating to mortgaged properties that are both commercial and residential properties.

Therefore for completeness, we have addressed the situation where the borrower's property would be an input taxed supply - that is a supply of residential premises as set out in section 40-65 of the GST Act, other than commercial or new residential premises.

Where section 105-5 of the GST Act does not apply because the supply of the borrower's property would be an input taxed supply, the entity's acquisition of various services directly referable to its input taxed supply will not be for a creditable acquisition. This is because the services acquired relate to making a supply that is input taxed and in accordance with paragraph 11-15(2)(a) of the GST Act, is not for a creditable purpose.

In this situation this entity will not be eligible for a full input tax credit under section 11-20 of the GST Act. Also the entity will not be able to claim a reduced input tax credit for acquisitions because they do not relate to making a supply that is input taxed by virtue of it being a financial supply. For the reduced credit acquisition provisions to apply, the acquisitions must relate to making financial supplies.

Note: The entity did not ask us to address the supply of commercial/residential premises under Division 105 of the GST Act therefore a response was not provided. For more information on the supply of commercial/residential premises please refer to Goods and Services Tax Ruling: GSTR 2000/20: Goods and Services Tax: commercial residential premises.

Issue 4

This entity enters into loan agreements with borrowers who are required to repay a loan but do not own the property they have borrowed against.

On analysis of the loan agreement if the borrower defaults, the loan agreement operates so that the guarantor has to repay the money which the borrower owes.

This default event occurs at a point in time prior to possession taking place.

The loan agreement indicates the entity (lender) can ask the guarantor to give them a mortgage and certificate of title so the mortgage can be registered. The loan agreement also allows the lender to lodge a caveat on the title to a guarantor's property in order to recover the borrower's outstanding debt.

Division 105 of the GST Act refers to the supply of the property of another entity (the debtor) in or towards satisfaction of a debt that the debtor owes to the supplier (italics added). This seems to require an identity between the owner of the property which is supplied and the person who owes the relevant debt.

This promise by the mortgagor to pay the secured debt if the borrower defaults is supported by the loan agreement.

Therefore when this entity serves notice on the mortgagor (guarantor), the guarantor would be separately liable for the relevant debt so bringing the sale of the property within Division 105 of the GST Act.

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