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Edited version of private ruling
Authorisation Number: 1011696325464
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Ruling
Subject: Book keeping for global gaming calculations
Question
Can the payout ticket be destroyed after one month relying on the company's reconciliation of gaming revenue as evidence of calculation of the global gaming amount for GST and satisfying requirements for keeping records to determine the clubs GST liability?
Answer
Yes, the payout ticket can be destroyed after one month relying on the company's reconciliation of gaming revenue as evidence of calculation of the global gaming amount for GST and satisfying requirements for keeping records to determine the clubs GST liability.
Relevant facts and circumstances
This ruling is based on the facts stated in the description of the scheme that is set out below. If your circumstances are materially different from these facts, this ruling has no effect and you cannot rely on it. The fact sheet has more information about relying on your private ruling. The facts are as follows:
Gaming machine payouts to players are processed automatically by a Cash Redemption Terminal (CRT) similar in style to an automatic teller machine. A winning player is provided with a ticket from a gaming machine. Winning tickets of $500 and under can be paid automatically by a CRT without verifying the winning person's identity.
Printed tickets are used to provide payment and this information is stored in a database and printed daily to perform cash reconciliations and establish the gaming machine profit and loss for the day.
The company has provided a copy of the physical ticket which are generated and printed by a gaming machine in response to a winning event. The company proposes that only tickets that are under $500 processed by a CRT be identified for destruction.
Further information was provided and the company explained that the report for the CRT payouts was generated by the gaming server. The gaming server collates data from the gaming machine, that issue the payout ticket, as well as the CRT that pays out winnings on presentation of a payout ticket.
Relevant legislative provisions
Section 382-5 of the Taxation Administration Act 1953
Reasons for decision
Record keeping for GST is provided for under section 382-5 of the Taxation Administration Act 1953 (TAA). In particular, subsection 384-5(4) of the TAA provides, for amongst other things, for where you make a calculation under an indirect tax law, such as GST, you are required to keep records for 5 years containing particulars of the calculation. Furthermore, subsection 382-5(8) of the TAA provides that the records must enable your liabilities under the GST to be readily ascertained.
Further guidance is provided under the Fact Sheet titled, Record keeping in the pubs and clubs industry which the company has provided and are familiar with.
In the company's circumstance, it is proposing to destroy the payout tickets one month after it has completed the reconciliation and for record keeping purposes will rely on the reconciliation of gaming revenue as evidence of the calculation of income for calculating your global GST amount.
We also note that the company print out daily the list of tickets that have been presented to a CRT and paid out. This information is used for the company to do its cash reconciliation.
As such we agree that there is no requirement for the company to keep the actual ticket/s that are presented at a CRT for payout beyond one month. Hence, the company's record keeping in regard to its cash reconciliation that it uses to establish your gaming machine profit and loss for the day and further use for working out its global GST amount, satisfies the requirements of section 382-5 of the TAA.