TAXATION RULING NO. ST 2072

ST 2072

SALES TAX : DIVINYCELL SANDWICH

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FOI status:

PREAMBLE

Divinycell is an expanded plastics material based on polyvinyl which has properties that are specially designed for being used as a load bearing core in a sandwich structure. The sheeting on each side of the Divinycell which makes up the Divinycell Sandwich may be of stainless steel, wood, aluminium or reinforced plastics. The Divinycell Sandwich combines properties of strength, light weight, thermal insulation and resistance to aging. It can be used in all situations that demand high strength and light weight combined in one material such as material used in the construction of buildings, truck bodies, railway rolling stock, aircraft, ships and other vessels.

RULING

2. The Divinycell Sandwich has a multiplicity of uses, some of which may attract sales tax. There is not any provision in the First Schedule to the Sales Tax (Exemptions and classifications) Act for unconditional exemption for Divinycell Sandwich. However, Divinycell Sandwich is conditionally exempt under sub-item 83(3), First Schedule when sold for use in the construction or repair of, and wrought into or attached to as to form part of, buildings or other fixtures.

3. The Divinycell Sandwich would commonly be purchased for use as a raw material in the commerical production of other goods e.g. truck bodies, railway rolling stock, aircraft, ships and other vessels, in which cases it would be conditionally exempt under item 113, First Schedule.

COMMISSIONER OF TAXATION
27 March 1984

References

ATO references:
NO ST11/26 P6
BO Sydney 22B/D18/7

Date of effect:
Immediate

Subject References:
DIVINYCELL AND DIVINYCELL SANDWICH

Legislative References:
SALES TAX (EXEMPTIONS AND CLASSIFICATIONS) ACT SUB-ITEM 83(3), FIRST SCHEDULE
ITEM 113, FIRST SCHEDULE