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Edited version of your written advice
Authorisation Number: 1012754725309
Ruling
Subject: GST and travel cards
Question 1
Is the supply of the multi-currency prepaid travel cards (Travel Card) GST-free under item 4(a) in subsection 38-190(1) of A New Tax System (Goods and Services Tax) Act 1999 (GST Act)?
Answer
Yes.
Question 2
Is the supply of services by A to B under the Agreement GST-free under item 4(a) in subsection 38-190(1) of the GST Act?
Answer
Yes.
Relevant facts and circumstances
Travel Card
The Travel Card is a reloadable prepaid card which can be used anywhere in the world for cash withdrawals at ATMs displaying the appropriate logo and for the purchase of goods or services in-store and online at participating merchants. The supply of the Travel Card to the customer will be made by B as the issuer.
It is intended that the Travel Card will only be used by customers to acquire goods and services from merchants outside Australia or to make ATM withdrawals outside Australia. The Travel Card may be acquired by business travellers, leisure travellers and individuals visiting friends and family. It is also possible that it could be acquired in Australia and given to friends/family living overseas for use there.
Supply
The Travel Card can be loaded with value in Australian Dollars. Amounts loaded onto the Card can be held in two currencies. Amounts held in each currency are recorded separately. The total of these amounts at any given time represents the total funds available on the Travel Card.
The Travel Card is reloadable, which means that value can be reloaded (there are no limits to the number of reloads) until it expires. Cardholders do not earn interest on the value that is loaded.
The Travel Card is designed and is marketed primarily for use outside Australia. You advise that it is possible that there could be some incidental use of the Travel Card in Australia; for example, withdrawing any unused funds at ATMs. However, given the limited acceptance in Australia, you consider that it would currently have negligible use in Australia.
Supply of services
A and B have entered into the Agreement. Under the Agreement, A will sell the Travel Card as distributor for B to its customers and be responsible for providing various services to B.
A is to be the primary access point for Cardholder enquiries and complaints
Relevant legislative provisions
A New Tax System (Goods and Services Tax) Act 1999 section 38-190
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