Edited version of private ruling

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Ruling

Subject: GST and supply of international freight services

Subject

GST and supply of international freight services

Issue 1

Questions

Is an Australian resident company (you) making a taxable supply when you provide freight forwarding services (not including customs clearance and delivery) to an Australian entity (importer)?

Are you making a taxable supply when you provide freight forwarding services (including customs clearance and delivery) to an Australian entity (importer)?

Are you making a taxable supply when you provide freight forwarding services (arrival services only) to an Australian entity (importer)?

Are you making a taxable supply when you are requested by an Australian entity (importer) to provide them with freight forwarding services (including customs clearance and delivery)?

Are you making a taxable supply when you are requested by an Australian entity (importer) to provide them with freight forwarding services (not including customs clearance and delivery)?

Advice/Answers

No. The supply of freight forwarding services (not including customs clearance and delivery) is GST-free as it is part of a supply of transport of goods from outside Australia to the place of consignment in Australia. However if you invoice the customs broker for any services provided in Australia then these supplies may be taxable as they are supplied to another entity in Australia.

The international shipping component of this supply is GST-free as it is part of a supply of transport of goods from outside Australia to the place of consignment in Australia. The customs clearance services and delivery services may be taxable it they are supplied after the place of consignment is established.

Yes. You are making a taxable supply when you provide freight forwarding services (arrival services only) to an Australian entity (importer). This supply is not part of a supply of transport of goods from outside Australia thus the supply is taxable.

Yes. You are making a taxable supply when you provide freight forwarding services (including customs clearance and delivery) to an Australian entity (importer). This supply is not part of a supply of transport of goods from outside Australia thus the supply is done in Australia and is taxable.

No. The supply of freight forwarding services (not including customs clearance and delivery) is GST-free as it is part of a supply of transport of goods from outside Australia to the place of consignment in Australia.

Relevant facts

You are an Australian resident entity that is registered for GST in Australia.

You are an Australian Freight Forwarding company.

You have agency agreements with various Freight Forwarding companies located overseas.

You handle shipments which you control (that is where an Australian entity requests your services directly). You also provide shipments where requests come from non-resident entities.

You do not have contracts, you quote your potential clients rates, and they tell their suppliers to ship goods through your services.

You effectively buy space on vessels from vessel operators (shipping lines) and sell same to your clients at a margin.

Facts in relation to Q 1

A non-resident entity (your agent) requests that you provide freight forwarding services to an Australian entity (importer).

This supply of freight forwarding services includes arranging for the shipping of goods from overseas until the goods arrive at port.

You do not deal directly with the importer. The importer has their own customs broker and you are requested to invoice the customs broker for your supply of services. The customs broker is also an Australian resident entity.

You do not have an agreement with the importer or the customs broker; the request for your freight forwarding services comes from your non-resident agent, however you do not have a written agreement with this entity either.

You have provided a Bill of Lading for this transaction which states that a port in Australia is the foreign port of unloading.

Your involvement in this supply ends when the goods arrive at the wharf at the port in Australia.

You do not arrange for the customs clearance and delivery of the goods, this is done by the customs broker.

You incur origin charges, freight charges and arrival charges in relation to this supply.

You pass on these expenses that you incur and itemise them on your invoice to the customs broker and you charge a margin on top of these expenses.

You are making one supply of services to the importer.

Facts in relation to Q 2

A non-resident entity (your agent) requests that you provide freight forwarding services to an Australian entity (importer).

This supply includes arranging for the shipping of goods from overseas until the goods arrive at port here in Australia. You also arrange for the customs clearance and delivery of the goods in Australia, as part of the one supply to the importer.

You do not have a written agreement with the importer; the request for your freight forwarding services comes from your non-resident agent.

You have provided a Bill of Lading for this transaction which states that a port in Australia is the foreign port of unloading. The bill of lading advises that freight was prepaid.

Your involvement in this supply ends when the goods arrive at the importers premises here in Australia.

You incur origin charges, freight charges, arrival charges, customs clearance charges and local delivery charges in relation to this supply.

You pass on these expenses that you incur and itemise them on your invoice to the importer and you charge a margin on top of these expenses.

You are making one supply of services to the importer.

Facts in relation to Q 3

A non-resident entity (your agent) requests that you provide freight forwarding services to an Australian entity (importer).

This supply of freight forwarding services includes arranging for the arrival of the goods at a port in Australia. There is no international freight/shipping component in this supply.

You do not deal directly with the importer. The importer has their own customs broker and you are requested to invoice the customs broker for your supply of services. The customs broker is also an Australian resident entity.

You do not have a written agreement with the importer or the customs broker; the request for your freight forwarding services comes from your non-resident agent.

You have provided a Bill of Lading for this transaction which states that a port here in Australia is the foreign port of unloading.

Your involvement in this supply starts when the goods arrive at the wharf at port here in Australia.

You do not arrange for the customs clearance and delivery of the goods, this is done by the customs broker.

You incur arrival charges only in relation to this supply.

You pass on the expense that you incur and itemise the arrival charges on your invoice to the customs broker and you charge a margin on top of these expenses.

You are making one supply of services to the importer.

Facts in relation to Q 4

An Australian entity (importer) requests that you provide customs clearance and delivery services for them in relation to a shipment coming from overseas.

This supply does not require you to arrange for the shipping of goods from overseas. Your supply is to arrange for the customs clearance and delivery of the goods when the goods arrive at a port here in Australia, as part of the one supply to the importer.

You have provided a Bill of Lading for this transaction which states that the port in Australia is the place of delivery and the port of discharge.

Your involvement in this supply ends when the goods arrive at the importers premises here in Australia.

You charge for your customs clearance services and local delivery charges in relation to this supply.

You pass on these expenses that you incur and itemise them on your invoice to the importer and you charge a margin on top of these expenses. Generally there will be no margin on Origin, Freight and Arrival charges if they are incurred. These would be billed to your client at cost as a disbursement in this supply.

You are making one supply of services to the importer.

Facts in relation to Q 5

An Australian entity (importer) requests that you provide freight forwarding services to them in relation to a shipment coming from overseas.

This supply requires you to arrange for the shipping of goods from overseas.

You have provided a Bill of Lading for this transaction which states that a port here in Australia is the port of discharge and place of delivery. The terms are Ex Works (place of departure).

Your supply does not require you to arrange for the customs clearance and delivery of the goods when the goods arrive at the port in Australia.

Your involvement in this supply ends when the goods are available for collection (but not cleared through customs) at the port in Australia.

The request for your freight forwarding services comes from the Australian importer directly.

You have had prior communication with the Australian importer and you quoted them for the provision of Origin Charges, Freight charges and Arrival charges.

You incur origin charges, freight charges and arrival charges in relation to this supply.

You pass on these expenses that you incur and itemise them on your invoice to the importer and you charge a margin on top of these expenses.

You are making one supply of services to the importer.

Your ruling request seeks to clarify the GST treatment of the supply of the transportation services provided by you to other entities in the five scenarios outlined above.

Reasons for decisions

Issue 1

Question 1

Section 38-355 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) specifies the general rules for the GST-free supplies of international transport of goods and related matters. The purpose of this section is to allow only certain aspects of the supply of transportation of goods to be GST-free. It is not the intention of the legislation to exempt all costs of transport of goods from the imposition of GST. If you are registered or required to be registered and you acquire goods or services for a creditable purpose (for use in your business), then you are able to claim an input tax credit for the GST included in the price of the supply of the goods or services in accordance with section 11-5 of the GST Act.

Items 5 and 5A together in the table in section 38-355 of the GST Act allow for the GST-free transport of goods in certain circumstances as follows:

The third column of this table sets out supplies that are GST-free:

Paragraphs (a) and (b) of item 5, and item 5A, in the table in subsection (1) do not apply to a supply to the extent that the thing supplied is done in Australia, unless:

the *recipient of the supply:

is a *non-resident; and

(ii) is not in Australia when the thing supplied is done in Australia; or

the supply is done by the supplier of the transport of the goods from or to Australia (whichever is relevant).

In relation to the importation of goods, Item 5(b) in the table in subsection 38-355(1) of the GST Act ensures that the supply of the international transport from outside of Australia to the port or airport of final destination in Australia continues to be GST-free. However the GST-free treatment may extend beyond this point if the place of consignment includes any further leg of Australian transport.

Hence, the term 'place of consignment' is important in as much as it defines the limits of the
GST-free status afforded to international transport. The term is defined in section 195-1 of the GST Act:

place of consignment of goods means:

if the goods are posted to Australia - the place in Australia to which the goods are addressed; or

(aa) if the supplier of the goods is to deliver the goods in Australia - the place in Australia to which the goods are to be delivered under the contract for the supply of the goods; or

(ab) if:

neither paragraph (a) nor (aa) applies; and

the goods are to be transported into Australia by an entity supplying a transport service to an entity that is to import the goods into Australia;

the place in Australia to which the goods are to be delivered under the contract for the supply of the transport service; or

in any other case - the port or airport of final destination as indicated on the *transportation document.

The term 'transportation document' is also defined in section 195-1 of the GST Act as follows:

transportation document includes the following:

· a consignment note;

· a house bill of lading;

· an ocean bill of lading;

· a house air waybill;

· a master air waybill;

· a sea waybill;

· a straight line air waybill;

· a sub-master air waybill;

· other similar documents.

In addition, the Explanatory Memorandum to the Tax Laws Amendment (2010 GST Administration Measures No.3) Bill 2010 (EM) provides guidance for a transportation document. Paragraph 1.18 to 1.20 of the EM state:

The primary agreement for the importation of goods refers to the agreement under which goods are delivered into Australia under the contract for the supply of the goods or where a local entity brings the goods to Australia, the primary agreement is the agreement for the transport of the goods to Australia.

If goods from outside Australia are supplied to a local purchaser on 'delivered duty paid', 'delivered duty unpaid' or under 'cost, insurance and freight' terms, the primary agreement will be the supply agreement for the sale of the goods to the local purchaser. In contrast, the primary agreement under terms of trade involving 'free on board' will generally be the agreement between a transport company and a local importer in which the goods are transported from a foreign port or airport to the local importer.

The place where an Australian transport supplier delivers goods in Australia is the place of consignment for inbound goods from overseas if they can show that this is the final place in Australia to which the goods are required to be transported under the contract or arrangement for the international transport of the goods.

As the definition of 'transport documentation' refers to a document, the 'place of consignment' for goods transported into Australia will be determined with reference to a written agreement for the transport of goods to Australia. The agreement may be a verbal one as well as a written one for the initial provision of transport services, it could be an e-mail request to pick goods up outside Australia and deliver to a place in Australia - it does not have to be a formal written agreement. The bills of lading also set out terms and may indicate a place of consignment.

Once the place of consignment is decided, it will determine both:

the extent to which transport services and other services associated with bringing goods to Australia will be GST-free; and

the extent of the transport and other service costs that need to be included in calculating the value of a taxable importation (VoTI) needed to determine the GST liability on import.

You are arranging for the shipping of the goods from overseas. You do not have a written agreement with the non-resident entity which requests you provide the freight forwarding services. Similarly you do not have any other agreements with either the importer or the customs broker. Without agreements we are unable to determine the place in Australia to which the goods are to be delivered as part of the supply of the transport services (place of consignment).

You have provided transportation documentation in the form of a bill of lading which states that the foreign port of unloading is a port in Australia. Without an agreement we look to this transportation document and determine that the final destination is the port. Thus the place of consignment in relation to this supply is the wharf at port here in Australia.

You are not required to arrange for the customs clearance of the goods and advise that your involvement in this supply ends when the goods arrive at the wharf at port here in Australia.

You include arrival charges as part of this supply and invoice the customs broker for these services. However it is not clear from the documentation if the arrival charges are services that you provide before the place of consignment is established or after the goods arrive at the wharf at the port here in Australia.

Transport supplier who brings the goods to Australia

Provided the supply is made by the [same] entity that has been contracted to provide the international transport to Australia, the supply is GST-free for the transport supplier who bring the goods to Australia.

For transport supplies undertaken within Australia, this will not necessarily be the supplier that physically carries out the service. Supplies of loading, handling and other services that facilitate the international transport of goods by the supplier of the international transport supply will be
GST-free.

In the current case, the transport supplier will be you. The freight forwarding services that you supply (including origin charges and freight charges) to the importer in Australia are part of the overall supply of transport of goods from overseas, for which you invoice the customs broker. You are making a GST-free supply of the international transport of goods under paragraph (b) of item 5A in the table in subsection 38-355 (1) of the GST Act.

Please note although this supply is GST-free it must be included in the calculation of the VoTI.

Transport supplier may provide services in Australia to another entity

It is not clear from the transportation documentation that you provided if the arrival services are supplied by your entity before the place of consignment is established. We provide the following additional advice on the assumption that these supplies are provided in Australia after the place of consignment is determined.

Subsection 38-355(2) of the GST Act excludes certain supplies from being GST-free. The recipient of this supply is an Australian entity (Importer) who is not a non-resident entity that is not in Australia when you supply your freight forwarding services. The supply of the freight forwarding services are clearly a GST-free supply in their own right as this supply is not provided in Australia.

The recipient of this supply is an Australian entity (Importer) who is not a non-resident entity that is not in Australia when you supply your arrival services. The supply of the freight forwarding services are clearly a GST-free supply in their own right as this supply is not provided in Australia.

However subsection 38-355(2) negates the GST-free status of freight forwarding services that are supplied in Australia unless they are provided to a non-resident or as part of an overall supply. You advise that you provide the freight forwarding services to the Australian entity (importer). In the absence of any agreement with this entity we cannot determine if these services are part of the same supply of the transport of the goods. You invoice the customs broker (an Australian entity), for the supply of these freight forwarding services. If these freight forwarding services (not including customs clearance and delivery) are provided in Australia and are provided after the place of consignment is established then these supplies are taxable.

Q 2

Please refer to the explanation already provided in relation to the Reasons for decisions for question 1.

Place of Consignment

In this scenario you arrange for the shipping of the goods from overseas and will also arrange for the customs clearance and delivery of the goods. You do not have a written agreement but have provided transportation documentation in the form of a bill of lading which states that the foreign port of unloading is here in Australia. Your involvement in this supply ends when the goods arrive at the importers premises in Australia.

The place of consignment will be determined from the trading terms that have been agreed with the seller and the buyer to bring the goods to Australia. In this case the bill of lading does not state the trading terms or the type of move, but describes the freight as prepaid. Accordingly the place of consignment is considered to be the final place in Australia to which the goods are required to be transported as per this agreement. You will need to determine the final place of consignment from your agreement with the importer and the supplied transport documentation.

Shipping of goods from overseas

The transport supplier will be you. The freight forwarding services (consisting of shipping of goods from overseas) that you supply to the importer in Australia is part of the overall supply of the transport of goods from overseas. You are making a GST-free supply of the international transport of goods under paragraph (b) of item 5A in the table in subsection 38-355 (1) of the GST Act.

Please note that the GST-free part of any international transport service must be included in the calculation of the VoTI.

Customs Clearance and Delivery of goods in Australia

If you provide this service to the importer at their request as part of your agreement to bring the goods to Australia, then the supply will be GST-free and included in the VoTI. If these activities occur after the arrival of the goods at the place of consignment then this will be a taxable supply to the importer. Whilst you have been appointed to supply the international transport of goods, it is necessary to determine whether these supplies (customs clearance and delivery of goods) are being made in connection with the international transport before or after the place of consignment.

A supply is a taxable supply if all the conditions under section 9-5 of the GST Act are satisfied. Section 9-5 of the GST Act states:

You make a taxable supply if:

· you make the supply for *consideration; and

· the supply is made in the course or furtherance of an *enterprise that you *carry on; and

· the supply is *connected with Australia; and

· you are *registered, or *required to be registered.

However, the supply is not a *taxable supply to the extent that it is *GST-free or *input taxed.

(The asterisks in this ruling indicate terms defined under section 195-1 of the GST Act.)

In relation to your supply of customs clearance and delivery of goods the requirements in paragraphs (b), (c) and (d) of section 9-5 of the GST Act are satisfied and assuming that any supply made will not be GST-free or input taxed, the relevant criterion to be resolved is the requirement in paragraph 9-5(a).

To satisfy the requirement of paragraph 9-5(a) of the GST Act there must be a supply and consideration, and there must be a sufficient connection between the two.

Subsection 9-10(1) of the GST Act defines a supply as any form of supply whatsoever.

The intended scope of subsection 9-10(1) of the GST Act is more fully illustrated in subsection
9-10(2) of the GST which states that without limiting subsection 9-10(1) of the GST Act, supply includes any of these:

· a supply of goods;

· a supply of services;

· a provision of advice or information;

· a grant, assignment or surrender of *real property;

· a creation, grant, transfer, assignment or surrender of any right;

· a *financial supply;

an entry into, or release from, an obligation:

· to do anything;

· to refrain from an act; or

· to tolerate an act or situation;

(h) any combination of any 2 or more of the matters referred to in paragraphs (a) to (g).

Therefore, a supply is something that passes from one entity to another. The supply may be one of particular goods, services or something else that is reflected in an agreement by one party to do something for another. This view is contained in Goods and Services Tax Ruling GSTR 2006/9 titled 'supplies' which sets out a number of propositions for characterising and analysing supplies.

'Consideration' is defined under section 9-15 of the GST Act. The definition extends beyond payments to include such things as acts and forbearances to act. A payment will be consideration for a supply if the payment is 'in connection with', 'in response to' or 'for the inducement' of the supply.

Following on from the above discussion we take the view that the customs clearance and delivery services have amounted to a 'supply' of the services under section 9-10 of the GST Act. We also take the view that such a supply is being made for consideration as there is sufficient nexus between the payment for the supply of the services.

Goods and Services Tax ruling GSTR 2001/8 sets out the view of the Commissioner on apportioning the consideration for a supply that includes taxable and non-taxable parts. GSTR 2001/8 is a public ruling which is the highest form of technical interpretative advice issued by the Tax Office and represents the Commissioner's view of the operation of the GST legislation. It provides certainty for taxpayers in conducting their business activities.

GSTR 2001/8 discusses the concepts of a mixed supply and a composite supply and differentiates between mixed and composite supplies. At paragraph 15 of the ruling it states:

You need to consider all of the circumstances of a supply to work out whether the supply is mixed or composite. GST is only payable on the taxable part of a mixed supply. If a composite supply is taxable, then GST is payable on the whole supply. If a composite supply is non-taxable then no GST is payable on the supply.'

Paragraph 16 of the ruling discusses the concept of a mixed supply:

A mixed supply is a supply that has to be separated or unbundled as it contains separately identifiable taxable and non-taxable parts that need to be individually recognised. Paragraphs 45 to 54 provide further explanation on what amounts to be separately identifiable parts of a supply.

The concept of a composite supply is discussed in paragraph 17 of the ruling:

If you make a supply that contains a dominant part and the supply includes something that is integral, ancillary or incidental to the part, then the supply is composite. You treat a composite supply as a supply of a single thing. Paragraphs 55 to 63 provide further explanation on integral, ancillary or incidental parts of a supply.

The ruling concludes at paragraph 20 in differentiating between mixed and composite supplies:

The distinction between parts that are separately identifiable and things that are integral, ancillary or incidental, is a question of fact and degree. In deciding whether a supply consists of more than one part we take the view that you adopt a commonsense approach.

In light of the guidance provided in GSTR 2001/8, the supply of the services such as customs clearance, delivery and international transport is considered to be a mixed supply because the supply consists of separately identifiable parts that need to be recognised. Neither of these parts is integral, ancillary or incidental in relation to the whole supply of the international transport of goods as indicated in paragraph 17 of GSTR 2001/8.

Further, supplies of customs clearance and delivery services are not considered to be the facilitation of international transport as required under paragraph (b) of item 5A in the table in subsection 38-355(1) of the GST Act.

Any payment made in connection with the supply of these services (that is any payment made in response to or for the inducement of a supply) is considered to be consideration for the supply.

Therefore we conclude that customs clearance and delivery services supplied in connection with the supply of the international transport, are supplies that are made for consideration as there is a nexus between the payment and the supply of those services. As these supplies do not form part of the GST-free international transport of goods, they are taxable supplies.

Ascertaining costs for Customs Clearance and Delivery of goods in Australia

Where a supply with the above characteristics of a mixed supply exists, section 9-80 of the GST Act will allow apportionment between the supply that is partly taxable and partly GST-free. GSTR 2001/8 provides further guidance in relation to the application of an apportionment.

Reasonable methods of apportionment

Where there is no legislative provision specifying a basis for apportionment you may use any reasonable method to apportion the consideration to the parts of a mixed supply. However, the apportionment must be supportable by the facts in the particular circumstances.

What is a reasonable method of apportioning the consideration for a mixed supply depends on the circumstances of each case. In some cases, there will be only one reasonable method you may use.

Depending on your circumstances, you may use a direct or indirect method when apportioning the consideration for a mixed supply.

The method you choose should be based on a consideration of all the circumstances and not because it gives you a particular result. You may need to use different methods, or a combination of methods, for different supplies to ensure the appropriate amount of GST is payable. You need to keep records that explain all transactions and other acts you engage in that are relevant to supplies you make, including supplies that are GST-free and input taxed.

As noted above, costs for customs clearance and delivery will not form part of the VoTI for the importation of goods.

In conclusion, the international shipping component of this supply is GST-free as it is part of a supply of transport of goods from outside Australia to the place of consignment in Australia. The customs clearance services and delivery services may be taxable if they are supplied after the place of consignment is established.

Q 3

Please refer to the explanation already provided in relation to the Reasons for decisions for question 1 and question 2 in addition to the following information.

Freight Forwarder who does not bring the goods to Australia

A freight forwarder (subcontracting entity) who only provides transport services within Australia will make a taxable supply. This is because it will be contracted to an entity that is in Australia when it makes the supply.

As discussed, any transport services that occur after arrival at the place of consignment are not international transport. Additionally, loading, handling and other services that facilitate transport services that occur after arrival at the place of consignment do not facilitate international transport and therefore will not be GST-free.

The subcontracting entity will be you. There is no International freight/shipping component in this supply. Your involvement commences when the goods arrive at the wharf at port in Australia. You have provided a Bill of Lading which states that the goods are supplied on a 'Pier to Pier' basis and the freight has been prepaid. The port of unloading is a port in Australia. You are not involved in the international shipping component of this supply. Your services are required when the goods arrive at the wharf at port in Australia. From the documentation provided the wharf in Australia is the place of consignment in relation to the transport of these goods.

As you are not bringing the goods from overseas, your supply of arrival services occurs after the place of consignment has been established. Thus your supply is not considered to be part of the overall supply of the transport of goods from overseas.

Consequently, your supply of freight forwarding services (arrival services only) will not be a
GST-free supply under section 38-355 of the GST Act.

Your supply of freight forwarding service meets the requirements of paragraphs 9-5 (a) to 9-5 (d) of the GST Act for the following reasons:

· your supply of freight forwarding services is for consideration

· the supply is in the course or furtherance of your enterprise

· the supply is connected with Australia as you make the supply through an enterprise that you carry on in Australia and

· you are registered for GST.

The supply of freight forwarding services is not input taxed. We have already determined that the supply is not a GST-free supply under section 38-355 of the GST Act. Therefore the supply is a taxable supply.

Q 4

Please refer to the explanation already provided in relation to the Reasons for decisions for question 1 and question 3.

You will provide customs clearance and delivery services in relation to a shipment. There is no international freight/shipping component in this supply. Your involvement commences when the goods arrive at the wharf at port here in Australia. You are not able to provide any documentation in relation to the international shipping component of this supply. You can only advise that your services are required when the goods arrive at the wharf at port here in Australia. Whilst we cannot conclusively establish the place of consignment without documentation from the other parties, we consider the wharf in Australia is most likely the place of consignment in relation to the transport of these goods.

As you are not bringing the goods from overseas, your supply of freight forwarding services (including customs clearance and delivery) occurs after the place of consignment has been established. Thus your supply is not considered to be part of the overall supply of the transport of goods from overseas.

Consequently, your supply of freight forwarding services (including customs clearance and delivery) will not be a GST-free supply under section 38-355 of the GST Act.

Q 5

Please refer to the explanation already provided in relation to the Reasons for decisions for question 1.

You are arranging for the shipping of the goods from overseas at the request of an Australian entity (importer). You are not required to arrange for the customs clearance and delivery of the goods. Your involvement in the supply ends when the goods are available for collection (but not cleared through customs) at the port here in Australia. Thus the place of consignment in relation to this supply is the port in Australia.

As explained supplies of freight forwarding services (not including customs clearance and delivery) that facilitate the international transport of goods by the supplier will be GST-free.

The transport supplier will be you. The freight forwarding services (not including customs clearance and delivery) that you supply to the importer in Australia is part of the overall supply of the transport of goods from overseas. You are making a GST-free supply of the international transport of goods under paragraph (b) of item 5A in the table in subsection 38-355 (1) of the GST Act.