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Edited version of private advice
Authorisation Number: 1051523230229
Date of advice: 13 June 2019
Ruling
Subject: GST and supply of services
In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided:
The Commissioner has ruled on each of the specific questions.
Question 1
Are the supplies of services by Entity A out of scope of section 9-5 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) on the basis that the services are not connected with the indirect tax zone?
Answer
No. The supplies of services by Entity A are connected with the indirect tax zone and are therefore within the scope of section 9-5 of the GST Act.
Question 2
(a) If the answer to Question 1 is "no", are Entity A's supplies of services only partly connected with the indirect tax zone to the extent that the services are made through an enterprise carried on in Australia and/or done in Australia?
(b) If the answer to Question 2(a) is "yes", is a time based apportionment methodology considered by the Commissioner to be a fair and reasonable method for Entity A to adopt in Entity A's facts and circumstances to determine the extent to which GST is payable on Entity A's supplies of services
Answers
(a) No. The supplies of services by Entity A are not partly connected with the indirect tax zone.
(b) Response is no longer required.
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