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Edited version of your written advice
Authorisation Number: 1051382825460
Date of advice: 6 July 2018
Ruling
Subject: Currency swaps
Question 1
Is a supply via a swap of circulating coin an input taxed supply pursuant to section 40-100 of the GST Act?
Answer
As a currency swap is at face value, the swap transaction is not a taxable supply, pursuant to subsection 9-10(4) of the GST Act.
Question 2
Who hold legal title over the coins?
Answer
As advised this is a contractual law matter that may only be determined by reviewing the relevant contracts.
Question 3
Do you need to lodge one consolidated BAS with the ATO?
Answer
As advised, this is not a question of law and it is an administrative matter for you to determine.
Legislative provisions
A New Tax System (Goods and Services Tax) Act 1999 subsection 9-10(4)
A New Tax System (Goods and Services Tax) Act 1999 Subdivision 40-D
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