Goods and Services Tax Ruling

GSTR 2006/9A6 - Addendum

Goods and services tax: supplies

Addendum

This Addendum is a public ruling for the purposes of the Taxation Administration Act 1953. It amends Goods and Services Tax Ruling GSTR 2006/9 to reflect amendments made to the A New Tax System (Goods and Services Tax) Act 1999 by the Tax and Superannuation Laws Amendment (2012 Measures No. 1) Act 2012.

The Addendum also amends GSTR 2006/9 to update the Case references.

GSTR 2006/9 is amended as follows:

1. Paragraphs 180

After the paragraph, insert:

180A. Where a third party makes a payment, the recipient of the supply does not necessarily need to be aware of that payment for that payment to be consideration for a supply made to the recipient.[54A] However, the knowledge of the recipient is one of the facts and circumstances of the arrangement that may be relevant in establishing if a payment by a third party forms part of the consideration for the supply to the recipient.
180B. Further, in identifying the character of the connection, the word 'for' ensures that not every connection between supply and consideration meets the requirements for a taxable supply. That is, merely having any form of connection of any character between a supply and payment of consideration is insufficient to constitute a taxable supply.[54B]

2. Case references

Insert:

-
AP Group Limited v. Commissioner of Taxation [2013] FCAFC 105; 2013 ATC 20-417; (2013) 214 FCR 301
-
AP Group Limited v. Commissioner of Taxation [2012] AATA 409; (2012) 83 ATR 493; 2012 ATC 10-256

This Addendum amends GSTR 2006/9 to explain the Commissioner's view of the law as it applies both before and after the date of issue.

Commissioner of Taxation
20 August 2014

© AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA

You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Footnotes

See AP Group Limited v. Commissioner of Taxation [2013] FCAFC 105 at [44] and AP Group Limited v. Commissioner of Taxation [2012] AATA 409 at [100 101].

See AP Group Limited v. Commissioner of Taxation [2013] FCAFC 105 at [33].

References

ATO references:
NO 1-55TNUY2

ISSN: 1443-5160