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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: 1051804013300

Date of advice: 26 February 2021

Ruling

Subject: GST and payments between government related entities

Question

Are the fees (Fees) paid by other government related entities (GREs) to you subject to goods and services tax (GST)?

Answer

No, the Fees paid by other GREs to you are not subject to GST. This is because the payment of such Fees are not the provision of consideration by virtue of subsection 9-17(3) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act).

Relevant facts and circumstances

You sought a private ruling on whether certain fees paid by other GREs to you under your described arrangements are subject to GST, and the Commissioner has ruled that the fees are not subject to GST.