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Edited version of your private ruling
Authorisation Number: 1012520847650
Ruling
Subject: Are the supplies GST free
Questions
1. Are the following supplies made by the entity as outlined in Table 1 below, in relation to the products also outlined in Table 1, GST-free under paragraph (a) of item 4 in subsection 38-190(1) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act)?
Supplies made by the entity |
Product |
Foreign currency conversion service |
Bank notes |
Foreign currency conversion service |
Cash Passport |
Foreign currency conversion service |
Travellers' Cheques |
· Until a certain date - Supply of Bank drafts · After a certain date - foreign currency conversion service |
Bank Drafts |
· Until a certain date - Supply of Wires (telegraphic transfers) · After a certain date- foreign currency conversion service |
Wires (telegraphic transfers) |
Table 1
2. Is the entity's proposed treatment of the 'acquisition supplies' consistent with the view held by the Commissioner?
3. Is the apportionment methodology proposed by the entity a fair and reasonable method of determining the extent of creditable purpose of the acquisitions made by the entity retrospectively and on an ongoing basis?
Decisions
The Commissioner made the following ruling.
1. The entity's supplies are GST-free under paragraph (a) of item 4 in subsection 38-190(1) of the GST Act as follows:
Product |
Supplies made by the entity |
The extent to which the supplies made by the entity is GST-free |
Bank notes |
Foreign currency conversion service |
Foreign currency conversion service supplied by the entity is GST-free where the entity coverts AUD into foreign currency and the foreign currency is for use outside of Australia |
A certain type of card |
Foreign currency conversion service |
The foreign currency conversion service supplied by the entity in relation to the card is GST-free to the extent the card is loaded in foreign currency and intended to be used by a cardholder outside Australia. |
Travellers' Cheques |
Foreign currency conversion service |
GST-free |
Bank Drafts |
Supply of Bank drafts and foreign currency conversion service |
GST-free |
Wires (telegraphic transfers) |
Supply of Wires (telegraphic transfers) and foreign currency conversion service |
GST-free |
Table 2
2. The entity is required to identify/classify the outbound and inbound transactions as outlined in Goods and service tax determination GSTD 2012/5 in determining whether or not a particular acquisition relates to the relevant foreign exchange transactions and acquisition supplies.
3. We are of the view that the proposed methodology which continues to use a value based approach provides a fair and reasonable allocation of the costs.