Disclaimer 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: 1051932942270
Date of advice: 23 February 2022
Ruling
Subject: GST and financial supplies
Question
You sought a private ruling on whether you make a supply of an interest in a debt pursuant subsection 40-5.09(1) of the A New Tax System (Goods and Services Tax) Regulations 2019 (GST Regulations), and also whether the nature of the funding you received constitutes a 'recoupment' of research & development expenditure for the purpose of section 355-440 of the Income Tax Assessment Act 1997 (ITAA1997).
Answer
The Commissioner has provided answers to the issues you sought clarification on.
Facts and circumstances
You are a party to a funding arrangement.