| Disclaimer This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law. You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4. |
Edited version of your private ruling
Authorisation Number: 1012592049953
NOTICE
This private ruling was revised following issue. This edited version has therefore been replaced with the edited version of the private ruling with the authorisation number of 1051617667301.
Ruling
Subject: GST and Apportionment
The ruling concerned the fair and reasonableness of an apportionment methodology and the Commissioner has ruled in the following way:
Question 1
Is the revised apportionment methodology for the retail credit card business of Entity A, fair and reasonable for calculating the amount of input tax credits it is entitled to for its acquisitions, for the purposes of Division 11 and Division 15 of the A New Tax System (Goods And Services Tax) Act 1999 (the GST Act)?
Answer
The Commissioner considers that the revised apportionment methodology for the retail credit card business of Entity A is, on balance, likely to provide a fair and reasonable basis for calculating the amount of input tax credits it is entitled to for its acquisitions for the purposes of Division 11 and Division 15 of the GST Act.
Question 2
Can Entity A calculate and apply the revised apportionment methodology on an annual basis?
Answer
Yes, Entity A can calculate and apply the revised apportionment methodology on an annual basis, provided this does not result in a distortion of the outcome.
Question 3
Can Entity A implement its revised apportionment methodology with effect from a particular date?
Answer
With the exception of one tax period, notification of which was not received within time, Entity A can implement its revised apportionment methodology with effect from the particular date provided all normal requirements of the ATO in relation to substantiation of the revised methodology are met.