Disclaimer This edited version has been archived due to the length of time since original publication.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 private advice
Authorisation Number: 1051617667301
Date of advice: 18 December 2019
NOTICE
This is an edited version of a revised private ruling. It replaces the edited version of the private ruling with the authorisation number 1012592049953.
Your private ruling has been replaced
Ruling
Subject: GST and methodology to determine the extent of creditable purpose of acquisitions
The Commissioner issued a revised private ruling that the taxpayer's apportionment methodology is not a fair and reasonable basis for determining the extent of creditable purpose of its acquisitions because the methodology does not give a fair and reasonable reflection of the extent of the relationships between the relevant acquisitions and supplies made by the taxpayer.
This ruling applies to:
tax periods commencing on or after 1 January 2020
Relevant legislative provisions
A New Tax System (Goods and Services Tax) Act 1999 section 11-5
A New Tax System (Goods and Services Tax) Act 1999 section 11-15
A New Tax System (Goods and Services Tax) Act 1999 section 15-5
A New Tax System (Goods and Services Tax) Act 1999 section 15-10
Taxation Administration Act 1953 subsection 359-55(1) of Schedule 1
Taxation Administration Act 1953 subsection 359-55(5) of Schedule 1