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Edited version of your private ruling
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Ruling
Subject: GST and apportionment of input tax credits
The commissioner was asked to rule on the following issue:
Question
Is the entity's proposed transaction based apportionment methodology fair and reasonable?
Answer
The proposed apportionment methodology, without recognition of the greater rate/proportion of the costs consumed by the input taxed products and recognition of the resources utilised to administer the investments, is not a fair and reasonable reflection of the extent of creditable purpose of those costs that have a particular GST Code.
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