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This edited version has been archived due to the length of time since original publication.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 written advice

Authorisation Number: 1051413803361

Date of advice: 10 August 2018

Ruling

Subject: Goods and services tax

The Commissioner has ruled on each of the following questions.

Question 1

Does Entity A, in its capacity as responsible entity for trust A make a reduced credit acquisition where Advisers provide Adviser Services?

Question 2

Does Division 84 of A New Tax System (goods and Services Tax) Act 1999 (GST Act) apply where Entity A acquires supplies of Adviser Services from non-resident Advisers for supplies not connected with the indirect tax zone?

Relevant legislative provisions

A New Tax System (Goods and Services Tax) Act 1999:

Section 9-5

Section 11-5

Section 11-15

Section 40-5

Section 70-5

Section 70-10

Division 84

Section 84-5

A New Tax System (Goods and Services Tax) Regulations 1999:

Subregulation 40-5.09(3)

Regulation 70-5.02

Subregulation 70-5.02(2) item 32