Goods and Services Tax Ruling
GSTR 2009/4A3 - Addendum
Goods and services tax: new residential premises and adjustments for changes in extent of creditable purpose
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Addendum
This Addendum is a public ruling for the purposes of the Taxation Administration Act 1953. It amends Goods and Services Tax Ruling GSTR 2009/4 following the Administrative Appeals Tribunal (AAT) decision in Domestic Property Developments Pty Ltd as trustee for the Dals Property Trust and Commissioner of Taxation [2022] AATA 4436. In particular, the updates reflect that the AAT confirmed that marketing premises for sale is a 'use' of premises for the purposes of section 40-75 of the A New Tax System (Goods and Services Tax) Act 1999 (the GST Act). However, the AAT clarified that the meaning of 'applied' in Division 129 of the GST Act and 'used' should not be interpreted consistently as a matter of course, and that 'used' takes its ordinary meaning.
Other amendments to GSTR 2009/4 reflect updates in line with current ATO accessibility requirements.
GSTR 2009/4 is amended as follows:
Omit the preamble; substitute:
This publication is a public ruling for the purposes of the Taxation Administration Act 1953.
If this Ruling applies to you, and you correctly rely on it, we will apply the law to you in the way set out in this Ruling. That is, you will not pay any more tax or penalties or interest in respect of the matters covered by this Ruling.
Omit the Table of Contents; substitute:
| Table of Contents | Paragraph |
| What this Ruling is about | 1 |
| Date of effect | 4 |
| Background | 7 |
| Previous Rulings | 10 |
| Legislative context | 11 |
| Ruling with explanation | 23 |
| Determining whether an acquisition made in constructing new residential premises is a creditable acquisition for the purposes of Division | 23 |
| Example 1 – partly input taxed and partly creditable planned use | 26 |
| When is a thing applied in carrying on an entity's enterprise? | 30 |
| Determining the extent to which new residential premises have been applied for a creditable purpose | 36 |
| Example 2 – premises not held for the purpose of sale as part of an enterprise | 42 |
| Demonstrating that new residential premises are being held for sale in an entity's enterprise | 44 |
| Partially completed residential property developments | 47A |
| Example 2A – application for a creditable purpose of acquisitions incorporated into partially completed residential premises | 47G |
| Partially completed multi-stage residential property developments | 47J |
| Dual applications of new residential premises | 48 |
| Example 3 – dual concurrent applications - new residential premises applied for creditable and non-creditable purposes at the same time | 54 |
| Example 3A – dual concurrent application – partially completed multi-stage development comprising residential units being concurrently applied for creditable and non-creditable purposes | 57A |
| Example 4 – consecutive different applications - new residential premises applied for a creditable purpose and then for a non-creditable purpose | 58 |
| Example 4A – consecutive different applications - multi-stage development comprising new residential premises that are applied for a creditable purpose and then for a non-creditable purpose | 60A |
| Calculating adjustments under Division 129 | 61 |
| The meaning of 'the thing' for the purposes of Divisions 11 and 129 | 62 |
| Example 5 – Division 129 and acquisitions made on a progressive basis | 65 |
| How does Division 129 apply with respect to the different types of acquisitions that can relate to the construction, sale and leasing of new residential premises? | 67 |
| Example 6 – acquisitions made in constructing new residential premises subject to adjustments | 69 |
| Example 7 – adjustments for repairs | 72 |
| Example 8 – acquisitions related solely to the creditable purpose of sale | 75 |
| Example 9 - overhead acquisitions related to the enterprise as a whole | 79 |
| Reasonable method of apportionment | 81 |
| Example 10 – output-based indirect method after the premises have been sold | 84 |
| Example 11 – premises applied for a creditable purpose, to some extent, for the entire relevant period | 92 |
| Example 12 – premises applied for 100% creditable purpose for part of the relevant period, and then subsequently applied for 0% creditable purpose for the remainder of the period | 98 |
| Example 13 – premises applied for a creditable purpose, to some extent, for part of the relevant period, and then subsequently applied for 0% creditable purpose for the remainder of the period | 103 |
| Apportionment of the extent of creditable purpose of acquisitions relating to a residential unit complex that comprises multiple stratum units | 108 |
| Example 14 – multiple stratum units constructed for sale with only some applied partly to a creditable purpose and partly to a non creditable purpose - acquisitions relating solely to one of the units and acquisitions relating equally to all units | 110 |
| Example 15 – multiple stratum units constructed for sale with only one applied partly to a creditable purpose and partly to a non-creditable purpose - acquisition relating to the units in different proportions | 116 |
| Application of residential premises to a private or domestic purpose | 121 |
| Example 16 – application to a private or domestic purpose | 122 |
| Summary of the output-based indirect method | 125 |
| Other methods of apportionment | 126 |
| Effective life | 128 |
| Depreciation | 130 |
| Change in projected sale price | 131 |
| Interaction between Division 129 and the '5-year rule' in subsection 40-75(2) | 132 |
| Alternative view | 136 |
| Example 17 – premises applied for the purpose of sale which do not satisfy the requirements of the '5-year rule' | 139 |
| Example 18 – premises held for the purpose of sale for a period of time and then used only to make input taxed supplies by way of lease | 142 |
| Further example | 145 |
| Example 19 – property development where premises are constructed for sale but leased prior to sale - worked example | 146 |
Omit the wording of the paragraph; substitute 'This Ruling applies to tax periods commencing both before and after its date of issue.'.
Omit footnote 1.
Omit the wording of footnote 2; substitute:
An entity may not be able to revise adjustments where the relevant tax periods are outside the relevant time limits specified in section 105 55 of Schedule 1 to the Taxation Administration Act 1953.
Omit 'GST'; substitute 'goods and services tax (GST)'.
Omit footnote 10.
Omit the wording of footnote 15; substitute:
See paragraph 45 of Goods and Services Tax Ruling GSTR 2000/24 Goods and services tax: Division 129 – making adjustments for changes in extent of creditable purpose.
(a) Omit 'the following table.'; substitute 'Table 1 of this Ruling:'.
(b) Omit the table; substitute:
| GST-exclusive value of the acquisition | Adjustment periods |
| $5,000 or less | 2 |
| $5,001 to $499,999 | 5 |
| $500,000 or more | 10 |
(a) After 'in this Ruling', insert a comma.
(b) Omit the wording of footnote 19; substitute:
Throughout this Ruling, all references are to an entity making input taxed supplies by way of lease. However, the Ruling also applies equally if an entity makes input taxed supplies of residential premises by way of hire or licence.
Omit 'commercial residential premises,'; substitute 'commercial residential premises;'.
Omit the wording of footnote 23; substitute:
If, prior to completion of construction, the entity decided to use the premises for residential rental rather than for the purpose of sale, some of the acquisitions may not be made solely for a creditable purpose. Refer to paragraphs 25 and 29 of this Ruling.
(a) Omit 'pick-up'; substitute 'pick up'.
(b) Omit 'market to improve.An objective'; substitute 'market to improve. An objective'.
Omit the wording of footnote 29; substitute:
For further detail on creditable purpose in the context of Division 11, refer to GSTR 2008/1.
(a) After 'Division 129', insert a comma.
(b) Omit the wording of footnote 32; substitute:
For discussion on the meaning of a 'thing' in the context of Divisions 11 and 129, see paragraphs 62 to 64 of this Ruling.
Omit the wording of footnote 37A; substitute:
As discussed at paragraphs 132 to 135 of this Ruling, if an entity has applied new residential premises for a creditable purpose in accordance with Division 129, the premises will also have been used other than for making supplies that are input taxed under paragraph 40-35(1)(a) and the requirements of the '5-year rule' in subsection 40-75(2) will not be satisfied.
Omit the wording of footnote 40; substitute:
Refer to comments of Bowen CJ in Ku-Ring-gai Co-Op Building Society (No 12) Limited [1978] FCA 107; 36 FLR 134 at [139].
(a) Omit 'GXCX v.'; substitute 'GXCX and'.
(b) Omit the wording of footnote 41A; substitute:
[2009] AATA 569.
(a) After 'In GXCX', insert a comma.
(b) After 'However', insert a comma.
After 'In such cases', insert a comma.
(a) Omit 'enterprise activities an entity may be developing and/or constructing new residential premises'; substitute 'enterprise activities, an entity may be developing or constructing new residential premises, or both'.
(b) After 'In some cases', insert a comma.
Omit 'enterprise, and pursuant to'; substitute 'enterprise and, pursuant to'.
Omit 'developed/constructed'; substitute 'developed or constructed'.
(a) After 'In some cases', insert a comma.
(b) Omit 'completed, individual'; substitute 'completed individual'.
(c) Omit the wording of footnote 41D; substitute:
Similar to the type of arrangement set out in paragraph 6 of Goods and Services Tax Ruling GSTR 2011/1 Goods and services tax: development, lease and disposal of a retirement village tenanted under a 'loan-lease' arrangement.
Omit the wording of footnote 41E; substitute:
As discussed at paragraphs 132 to 135 of this Ruling, if an entity has applied new residential premises for a creditable purpose in accordance with Division 129, the premises will also have been used other than for making supplies that are input taxed under paragraph 40-35(1)(a) and the requirements of the '5-year rule' in subsection 40-75(2) will not be satisfied.
Omit 'and/or'; substitute 'or'.
After 'For further details', insert a comma.
(a) After 'During the construction stage', insert a comma.
(b) After 'almost complete', insert a comma.
Omit 'interest only'; substitute 'interest-only'.
(a) After 'leasing the premises', insert a comma.
(b) After 'From this time', insert a comma.
Omit 'entire, completed'; substitute 'entire completed'.
After 'end of November', insert a comma.
(a) After 'In December', insert a comma.
(b) After 'Since this time', insert a comma.
(a) After 'end of November', insert a comma.
(b) After 'From December', insert a comma.
(c) After 'Therefore', insert a comma.
(d) After 'relevant adjustment period', insert a comma.
After 'refers to 'thing'', insert a comma.
Omit the wording of the paragraph; substitute:
While it is necessary to look at the application of the 'thing' into which the individual acquisitions have been incorporated, it is the individual acquisitions that are subject to adjustments under Division 129. Also, section 156-20 provides that for the purposes of Division 129, an acquisition by an entity that accounts otherwise than on a cash basis is treated as if each progressive or periodic component of the acquisition were a separate acquisition if it is made:
- (a)
- for a period or on a progressive basis; and
- (b)
- for consideration that is to be provided on a progressive or periodic basis.
(a) Omit 'GST inclusive'; substitute 'GST-inclusive'.
(b) Omit the bullet points; substitute:
- •
- Progress payment 1 – $45,000
- •
- Progress payment 2 – $45,000
- •
- Progress payment 3 – $65,000
- •
- Progress payment 4 – $65,000.
(a) Omit 'GST exclusive'; substitute 'GST-exclusive'.
(b) Omit 'materials such as bricks, concrete, roofing, paint, etcetera'; substitute 'materials, including such items as bricks, concrete, roofing and paint'.
After 'On one project', insert a comma.
After 'sell the premises quickly', insert a comma.
After 'While leasing the premises', insert a comma.
After 'premises for two years', insert a comma.
After 'sell the premises', insert a comma.
(a) After 'Alex's enterprise', insert a comma.
(b) After 'referred to above', insert a comma.
(c) In the last sentence, after 'particular premises', insert a comma.
After 'leasing the residential premises', insert a comma.
After 'apportion its creditable purpose', insert a comma.
(a) After 'under a loan-lease' arrangement', omit the comma.
(b) Omit 'as discussed in paragraphs 47A to 47I of this Ruling'; substitute '(as discussed in paragraphs 47A to 47I of this Ruling)'.
(c) Omit 'as discussed in paragraphs 47J to 47M of this Ruling'; substitute '(as discussed in paragraphs 47J to 47M of this Ruling)'.
(a) Omit 'output based'; substitute 'output-based'.
(b) Omit the formula; substitute:
consideration for the taxable supply of the premises ÷ (consideration for the taxable supple of the premises + consideration for the input taxed supplies of residential premises by way or lease)
(a) In the heading, omit 'output based'; substitute 'output-based'.
(b) After 'new premises was slow', insert a comma.
Omit the wording of the paragraph; substitute:
At the end of the next adjustment period following the sale, Jane calculates the extent of creditable purpose using the formula in paragraph 83 of this Ruling as $500,000 ÷ ($500,000 + $15,000) = 97.09%.
(a) Omit 'remains''; substitute 'remains'.
(b) After 'relevant adjustment period', insert a comma.
(c) Omit 'output based'; substitute 'output-based'.
52. Paragraphs 88, 89, 126 and 153
Omit 'output based'; substitute 'output-based'.
Omit 'GST inclusive'; substitute 'GST-inclusive'.
After '31 March 2007', insert a comma.
Omit the wording of the paragraph; substitute:
For the 15 months from 1 April 2007 to 30 June 2008, John has applied the premises for both a creditable purpose and a non-creditable purpose. John works out the extent of creditable purpose for the relevant period by using an output-based indirect method (using estimated sales consideration) of $500,000 ÷ ($500,000 + $37,500) = 93.02%.
(a) Omit 'output based'; substitute 'output-based'.
(b) Omit 'time based'; substitute 'time-based'.
After '31 March 2007', insert a comma.
After '30 June 2008', insert a comma.
(a) Omit 'time based'; substitute 'time-based'.
(b) Omit the formula; substitute:
(6 months ÷ 21 months × 100%)
= 28.57%.
Omit the wording of footnote 51; substitute:
John will need to make further adjustments in any subsequent relevant adjustment periods if he continues to apply the premises solely in relation to making input taxed supplies. If John later sells the premises, he may need to consider whether he is entitled to make a decreasing adjustment or whether subsection 40-75(2) applies if for at least five years the premises have only been used for making supplies by way of lease that are input taxed. See paragraphs 132 to 144 of this Ruling for further discussion of subsection 40-75(2).
(a) After '31 December 2007', insert a comma.
(b) After 'relevant period', insert a comma.
Omit the wording of the paragraph; substitute: John works out the extent of creditable purpose for the relevant period in two steps. First, John uses an output-based indirect method (using estimated sales consideration) of $500,000 ÷ ($500,000 + $37,500) = 93.02%.
Omit the wording of the paragraph; substitute:
John now needs to undertake a further apportionment to reflect the fact that the premises were not held for the purpose of sale for the entire relevant period. This is calculated by adjusting the percentage in paragraph 105 of this Ruling by the proportion of the relevant period for which the premises were being held for the purpose of sale – being 93.02% × 15 months ÷ 21 months = 66.44%.
(a) After 'purpose of sale', insert a comma.
(b) After 'particular stratum unit', insert a comma.
(c) After 'units constructed', insert a comma.
After 'construction of the units', insert a comma.
Omit the wording of the paragraph; substitute
Using the output-based indirect method, the extent of creditable purpose to which each of the units has been applied is $1,500,000 ÷ ($1,500,000 + $37,500) = 97.56%.
Omit the wording of the paragraph; substitute:
However, as unit 1 was applied solely for a creditable purpose it is necessary to ensure this is taken into account in determining the actual application of all of the four units for the purposes of determining the extent to which the acquisitions that relate equally to each of the four units have been applied for a creditable purpose. This is calculated by averaging the extent of creditable purpose calculated for each of the four units. That is:
Average = (Unit 1 + Unit 2 + Unit 3 + Unit 4) ÷ 4
= 98.17%
where:
- •
- Unit 1 – 100%
- •
- Unit 2 – 97.56%
- •
- Unit 3 – 97.56%
- •
- Unit 4 – 97.56%.
(a) After 'of the construction', insert a comma.
(b) After 'sell unit B and', insert a comma.
(c) After 'sell the unit', insert a comma.
Omit the wording of the paragraph; substitute:
Using the output-based indirect method, the extent of creditable purpose to which unit B has been applied is $600,000 ÷ ($600,000 + $22,500) = 96.39%.
(a) After 'related 40% to unit A', insert a comma.
(b) Omit all instances of 'output based'; substitute 'output-based'.
(c) After '= 97.83%', insert a full stop.
After 'In some cases', insert a comma.
Omit the wording of the paragraph; substitute:
At the end of the next adjustment period following the sale, Mary calculates the extent of creditable purpose using the formula set out in paragraph 83 of this Ruling for the output-based indirect method but uses the market value of rent as a notional value for her private and domestic application of the premises. So, $500,000 ÷ ($500,000 + $7,500) = 98.52%.
(a) In the heading, omit 'output based'; substitute 'output-based'.
(b) Omit all instances of 'output based'; substitute 'output-based'.
(c) Omit 'time based'; substitute 'time-based'.
(a) After 'reject this method', insert a comma.
(b) Omit the wording of footnote 51A; substitute:
In A Taxpayer and Commissioner of Taxation [2011] AATA 160 at [27], the Administrative Appeals Tribunal accepted the reasoning as set out in paragraph 128 of this Ruling as to why an apportionment method based on the effective life of residential premises is not considered to be fair and reasonable.
After 'In broad terms', insert a comma.
(a) In the heading, omit '5 year rule'; substitute '5-year rule'.
(b) Omit the paragraph.
(a) Omit all instances of '5 year'; substitute '5-year'.
(b) After 'is satisfied', insert a comma.
(a) Omit the wording of the paragraph; substitute:
'Used' is an important term in subsection 40-75(2). 'Used' takes its ordinary meaning in its context.51B As noted in paragraph 33 of this Ruling, there is a strong similarity between the ordinary meanings of 'use' and 'apply' in this context. That is, the relevant meanings are largely synonymous. If an entity has 'applied' new residential premises for a creditable purpose under Division 129 (for example, the entity held the premises for the purpose of sale), the premises will also have been 'used' other than for making supplies that are input taxed under paragraph 40-35(1)(a). In such circumstances, subsection 40-75(2) will not be satisfied.
(b) After 'in its context.', insert new footnote 51B:
51B Domestic Property Developments Pty Ltd as trustee for the Dals Property Trust and Commissioner of Taxation [2022] AATA 4436 at [44–47].
Omit the paragraph, including footnote 52.
(a) Omit the wording of footnote 53; substitute:
See, for example, Newcastle City Council v Royal Newcastle Hospital [1957] HCA 15; 96 CLR 493 at [515], per Taylor J; Ryde Municipal Council v Macquarie University [1978] HCA 58; 139 CLR 633 at [637], per Gibbs ACJ and at [651], per Stephen J.
(b) Omit 'It is considered that a broad interpretation of 'used' in subsection 40-75(2) to extend to any uses of the premises by the entity including applications for a creditable purpose by way of holding premises for the purpose of sale is consistent with the intended policy referred to in the Explanatory Memorandum (see paragraph 135 of this Ruling).'; substitute:
It is considered that a broad interpretation of 'used' in subsection 40-75(2) to extend to any uses of the premises by the entity including applications for a creditable purpose by way of holding premises for the purpose of sale is consistent with the intended policy. See the Revised Explanatory Memorandum to the Taxation Laws Amendment Bill (No. 8) 2000, which introduced section 40-75.53A
(c) After 'which introduced section 40-75.' insert new footnote 53A:
53A The policy intent, as explained at paragraphs 1.16 and 1.17 of the Revised Explanatory Memorandum to the Taxation Laws Amendment Bill (No. 8) 2000, was that new residential premises will not be taxable if an entity is not entitled to input tax credits for acquisitions relating to the construction of the premises.
(a) In the heading, omit '5 year rule'; substitute '5-year rule'.
(b) After 'On completion of the premises', insert a comma.
(a) After 'six months of this period', insert a comma.
(b) After 'Therefore', insert a comma.
(c) Omit all instances of '5 year'; substitute '5-year'.
Omit the headings before the paragraph; substitute 'Further example'.
Omit the wording of the paragraph, including heading; substitute:
Example 19 – property development where premises are constructed for sale but leased prior to sale – worked example
Facts
David, a property developer, is registered for GST and accounts for GST on a quarterly basis. David also accounts on a basis other than cash. The following occurs:
Table 2: Sequence of events Date Event 30 August 2006 David acquires a block of land for $220,000 (GST-inclusive). The margin scheme was not applied. 10 September 2006 David entered into a contract with a builder to construct new residential premises on the land. The contract price was $198,000 (GST-inclusive). 10 October 2006 David made a progress payment of $55,000. 31 January 2007 David made a progress payment of $77,000. 2 April 2007 David made a final payment of $66,000.
Omit the wording of the paragraph; substitute:
Each of the progress payments will be treated as a separate acquisition for the purposes of Division 129.57 The first adjustment period is a tax period that ends on 30 June and commences at least 12 months after the end of the tax period to which each acquisition was attributed. The relevant adjustment periods are as follows:
Table 3: Relevant adjustment periods Acquisition date Acquisition cost (GST-exclusive) First adjustment period Number of adjustment periods 30 August 2006 (land) $200,000 Tax period ending 30 June 2008 5 10 October 2006 (progress payment) $50,000 Tax period ending 30 June 2008 5 31 January 2007 (progress payment) $70,000 Tax period ending 30 June 2008 5 2 April 2007 (final payment) $60,000 Tax period ending 30 June 2009 5
After 'sale of the new residential premises', insert a comma.
(a) After 'until 30 June 2008', insert a comma.
(b) Omit 'output based'; substitute 'output-based'.
(c) After 'During this period', insert a comma.
(d) Omit the last sentence, including the formula; substitute:
The extent of creditable purpose for the relevant period up to 30 June 2008 is therefore $550,000 ÷ ($550,000 + $22,000) = 96.15%.
Omit the wording of the paragraph; substitute:
Applying the method statement in respect of the land:
- •
- Step 1 – The extent to which the thing has been applied for a creditable purpose during the period 30 August 2006 to 30 June 2008 is 96.15%.
- •
- Step 2 – The extent to which the thing was acquired for a creditable purpose is 100%, as the planned use at the time of the acquisition was not to make any input taxed supplies.
- •
- Step 3 – As the actual application of the thing acquired is less than the intended or former application of the thing, David will have an increasing adjustment.
Omit the wording of the paragraph; substitute:
Therefore, the increasing adjustment in respect of the land is calculated as follows:
$20,000 × (100% − 96.15%)
= $770.
Omit the formula; substitute:
$5,000 × (100% − 96.15%)
= $192.50.
Omit the formula; substitute:
$7,000 × (100% − 96.15%)
= $269.50.
After 'business activity statement', insert '(BAS)'.
(a) After '1 August 2007 until 30 June 2009', insert a comma.
(b) Omit 'output based'; substitute 'output-based'.
(c) After 'During this period', insert a comma.
(d) Omit the last sentence, including the formula; substitute:
The extent of creditable purpose for the relevant period up to 30 June 2009 is therefore $480,000 ÷ ($480,000 + $46,000) =91.25%.
(a) After '2 April 2007', insert a comma.
(b) Omit 'output based'; substitute 'output-based'.
Omit the wording of the paragraph; substitute:
Applying the method statement in respect of the land:
- •
- Step 1 – The extent to which the thing has been applied for a creditable purpose during the period 30 August 2006 to 30 June 2009 is 91.25%.
- •
- Step 2 – The intended or former application as calculated above for the adjustment period ending 30 June 2008 was 96.15%.
- •
- Step 3 – As the actual application of the thing acquired is less than the intended or former application of the thing, David will have an increasing adjustment.
Omit the formula; substitute:
$20,000 × (96.15% − 91.25%)
= $980.
Omit the formula; substitute:
$5,000 × (96.15% − 91.25%)
= $245.
Omit the formula; substitute:
$7,000 × (96.15% − 91.25%)
= $343.
Omit the formula; substitute:
$6,000 × (100% − 91.25%)
= $525.
Omit 'business activity statement'; substitute 'BAS'.
(a) Omit 'output based'; substitute 'output-based'.
(b) Omit the formula; substitute:
consideration for the taxable supply of the premises ÷ (consideration for the taxable supply of the premises + consideration for the input taxed supplies of residential premises by way of lease).
Omit the last sentence, including the formula; substitute:
The extent of creditable purpose under the formula is therefore $500,000 ÷ ($500,000 + $68,000) = 88.03%.
Omit the wording of the paragraph; substitute:
Applying the method statement in respect of the land:
- •
- Step 1 – The extent to which the thing has been applied for a creditable purpose during the period 30 August 2006 to 30 June 2010 is 88.03%.
- •
- Step 2 – The intended or former application as calculated above for the adjustment period ending 30 June 2009 was 91.25%.
- •
- Step 3 – As the actual application of the thing acquired is less than the intended or former application of the thing, David will have an increasing adjustment.
(a) Omit the wording of the paragraph; substitute:
In accordance with the formula in section 129-70, the increasing adjustment in respect of the land is calculated as:
$20,000 × (91.25% – 88.03%)= $644.
(b) Omit footnote 59.
Omit the formula; substitute:
$5,000 × (91.25% − 88.03%)
= $161.
Omit the formula; substitute:
$7,000 × (91.25% − 88.03%)
= $225.40.
Omit the formula; substitute:
$6,000 × (91.25% − 88.03%)
= $193.20.
Omit the wording of the paragraph; substitute:
David's overall GST position in relation to input tax credits and adjustments for the four acquisitions is as follows:
- •
- Land:
- –
- $20,000 input tax credit (30 September 2006 BAS)
- –
- $770 increasing adjustment (30 June 2008 BAS)
- –
- $980 increasing adjustment (30 June 2009 BAS)
- –
- $644 increasing adjustment (30 June 2010 BAS)
- –
- Net result – $17,606 credit
- •
- 10 October 2006 progress payment:
- –
- $5,000 input tax credit (31 December 2006 BAS)
- –
- $192.50 increasing adjustment (30 June 2008 BAS)
- –
- $245 increasing adjustment (30 June 2009 BAS)
- –
- $161 increasing adjustment (30 June 2010 BAS)
- –
- Net result – $4,401.50 credit
- •
- 31 January 2007 progress payment:
- –
- $7,000 input tax credit (31 March 2007 BAS)
- –
- $269.50 increasing adjustment (30 June 2008 BAS)
- –
- $343 increasing adjustment (30 June 2009 BAS)
- –
- $225.40 increasing adjustment (30 June 2010 BAS)
- –
- Net result – $6,162.10 credit
- •
- 2 April 2007 final progress payment:
- –
- $6,000 input tax credit (30 June 2007 BAS)
- –
- $525 increasing adjustment (30 June 2009 BAS)
- –
- $193.20 increasing adjustment (30 June 2010 BAS)
- –
- Net result – $5,281.80 credit.
Omit the paragraph.
This Addendum applies both before and after its date of issue.
Commissioner of Taxation
18 March 2026
References
ATO references:
NO 1-12ESP194