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This edited version has been archived due to the length of time since original publication.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: 1051460604585

Date of advice: 29 November 2018

Ruling

Subject: GST and supply of a debit card

Question 1

Are you making a taxable supply under section 9-5 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) when you begin charging a card fee to a customer?

Answer

Yes. You are making a taxable supply under section 9-5 of the GST Act when you begin charging a card fee to a customer.

Question 2

When a customer transfers the 'Initial Top-Up Amount’ to its debit card account, is that amount consideration for a supply that you make?

Answer

No. The transfer of the Initial Top-Up Amount is not consideration for a supply that you make to a customer.

Question 3

When a customer transfers by direct debit the ‘Additional Top-Up Amount’ to its debit card account, is that amount consideration for a supply you make?

Answer

No. The transfer of the Additional Top-Up Amount is not consideration for a supply that you make to a customer.

Question 4

When a debit card account is debited, upon using the debit card, when paying for goods or services you supply to a customer, is the amount debited consideration for a supply and the requirements of section 9-5 of the GST Act are satisfied?

Answer

Yes. The amount debited in a customer’s debit card account is consideration for a supply and you are making a taxable supply under section 9-5 of the GST Act unless the supply is GST-free.

Question 5

Are you making a financial supply when you accept the Initial Top-Up Amount and the Additional Top-Up Amount from a Customer?

Answer

No. You are not making a financial supply when you accept the Initial Top-Up Amount and the Additional Top-Up Amount from a Customer.

This ruling applies for the following periods:

from 1 July 2018

Relevant legislative provisions

A New Tax System (Goods and Services Tax) Act 1999 sections 9-5 and 40-5