Goods and Services Tax Ruling

GSTR 2000/31

Goods and services tax: supplies connected with Australia

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FOI status:

may be releasedFOI number: I 1021078

Preamble

What this Ruling is about

1. This Ruling is about 'supplies connected with Australia', which under the A New Tax System (Goods and Services Tax) Act 1999 ('the GST Act'), may be taxable supplies^[F1] and subject to GST.^[F2] All legislative references in this Ruling are to the GST Act unless otherwise stated.

2. The Ruling explains when a supply is connected with Australia under section 9-25. In particular, the Ruling looks at when a supply of goods, real property, or things other than goods or real property, is connected with Australia. It does not address whether a supply is a taxable supply.

3. While the Ruling does not address whether a particular supply is a taxable supply, we make reference to, and illustrate by way of examples, the effect of certain provisions on the question of whether a supply is a taxable supply, GST-free or input taxed. The provisions considered are:

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section 38-185 - exports of goods that are GST-free;

*

section 38-187 - leases or hire of goods for use outside Australia;

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section 38-190 - supplies of things other than goods or real property, for consumption outside Australia that are GST-free; and

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Division 84 - offshore supplies other than goods or real property.

4. In this Ruling we also outline the operation of Division 96 and section 156-15 in relation to supplies that are partly connected with Australia.

5. It is recognised in the Ruling that a supply of goods that is connected with Australia may give rise to a taxable supply and a taxable importation.^[F3] This is explained and illustrated in the Explanations section of the Ruling (see paragraphs 152 to 162). We also summarise in the Context section of the Ruling, the requirements for an importation of goods to be a taxable importation under Division 13 (refer paragraphs 27 to 33).

6. The Ruling does not address telecommunication supplies^[F4] or financial supplies.^[F5] Also, while the Ruling outlines the broad principles relating to all kinds of supplies connected with Australia (other than telecommunication or financial supplies), it does not specifically illustrate how these principles apply to cross-border electronic supplies.

7. Certain terms used in this Ruling are defined, or explained, in the definitions section of the Ruling. These terms, when first mentioned in the body of the Ruling, appear in bold type.

Date of effect

8. This Ruling applies on and from 8 July 1999 (the date of Royal Assent to the GST legislation) and may be relied on immediately.

Context of supplies connected with Australia

9. To assist you in understanding the GST consequences of a supply that is connected with Australia, we provide below an outline of the basic operation of the GST law in respect of:

*

taxable supplies;

*

GST-free supplies;

*

importations;

*

taxable supplies and taxable importations;

*

offshore supplies other than goods or real property; and

*

non-residents making supplies connected with Australia.

Taxable supplies

10. The concept of supplies 'connected with Australia' is relevant to determining whether a supply is a taxable supply and subject to GST. Under section 9-5 you make a taxable supply if:

(a)

you make the supply for consideration; and

(b)

the supply is made in the course or furtherance of an enterprise that you carry on; and

(c)

the supply is connected with Australia ; and

(d)

you are registered , or required to be registered.

However, the supply is not a taxable supply to the extent that it is GST-free or input taxed .

11. Section 9-25 defines when a supply is 'connected with Australia'. For the purposes of determining whether a supply is connected with Australia, section 9-25 makes a distinction between a supply of goods, a supply of real property and a supply of anything other than goods or real property. This is explored fully in the Ruling and Explanations sections of the Ruling.

12. The connection with Australia is one of the elements required to be satisfied before a supply is a taxable supply. However, a supply is not a taxable supply to the extent that it is GST-free.

GST-free supplies

13. Broadly speaking, provided certain conditions are met, goods that are exported, or supplies of services or things other than goods or real property, that are for consumption outside Australia are GST-free.

14. If a supply is GST-free, no GST is payable on the supply.^[F6] However, you can still claim an input tax credit for anything acquired or imported to make that GST-free supply.^[F7]

Export of goods

15. Even though a supply of goods is connected with Australia, if the goods are exported, that supply of goods may be GST-free under section 38-185.

16. Section 38-185 sets out supplies of goods which are GST-free exports. For example, Item 1 of the table in subsection 38-185(1) provides that a supply of goods is GST-free if the supplier exports the goods from Australia before, or within 60 days (or such further period as the Commissioner allows) after:

(a)

the day on which the supplier receives any of the consideration for the supply; or

(b)

if, on an earlier day, the supplier gives an invoice for the supply - the day on which the supplier gives the invoice.^[F8]

However, the supply is not GST-free if the supplier reimports the goods into Australia.^[F9]

Example 1 - GST-free export of goods

17. Vino, an Australian wine merchant, supplies wine to Epicure in France. Vino exports the consignment of wine from Australia 20 days after giving Epicure an invoice for the supply. The supply is GST-free because Vino (the supplier) exports the wine from Australia within 60 days after giving Epicure an invoice for the supply.

Example 2 - Export of goods by recipient

18. Live Ex, an Australian livestock company, supplies cattle to Stock Co, an Iranian company. Stock Co enters into an arrangement whereby it takes possession of the cattle consignment in Australia. This means that Live Ex does not export the cattle. Stock Co takes possession of the cattle consignment in Australia and arranges its freight to Iran.

19. The supply made by Live Ex to Stock Co is not GST-free because Stock Co (the recipient) exports the goods. For the export of goods to be GST-free, the supplier must export the goods. However, it is to be noted that subsection 38-185(3) sets out circumstances when exports are GST-free where ownership of goods passes to an overseas purchaser, who is not registered or required to be registered, before the goods are removed from Australia.

Leases etc of goods used outside Australia

20. Under section 38-187 a lease or hire of goods used outside Australia is GST-free. Specifically, the section provides that a supply of goods is GST-free if:

(a)

the supply is by way of lease or hire; and

(b)

the goods are used outside Australia.

The note to the section provides that if goods are leased or hired and used partly in Australia and partly outside Australia, the supply could be taxable to the extent that the goods are used in Australia (section 9-5).

Example 3 - GST-free supply of goods by way of lease

21. Aero Co (an Australian resident company) leases a light aircraft to Flite Co (an Australian resident company). The aircraft is used partly in Australia and partly in New Zealand. The supply by Aero Co is GST-free under section 38-187 to the extent that the goods are used outside Australia. A fair and reasonable basis of apportionment is to be adopted in working out the extent that the goods are used outside Australia.

Supplies of things other than goods or real property, for consumption outside Australia

22. Some supplies of things other than goods or real property, that are for consumption outside Australia are GST-free under Division 38.

23. Subsection 38-190(1) lists supplies of things that are GST-free. The GST-free supplies listed are:

Item 1

a supply that is directly connected with goods or real property situated outside Australia.

Item 2

a supply that is made to a recipient who is not an Australian resident and is not in Australia when the thing supplied is done (other than a supply directly connected with goods situated in Australia when the thing supplied is done, or with real property situated in Australia.

Indirect Tax Legislation Amendment Bill 2000 proposes to amend item 2 of subsection 38-190(1) so that, a supply will be GST-free if the supply is made to a non-resident who is not in Australia when the thing supplied is done and:

(a)

the supply is neither a supply of work physically performed on goods situated in Australia when the work is done nor a supply directly connected with real property situated in Australia; or

(b)

the non-resident acquires the thing in carrying on the non-resident's enterprise but is not registered or required to be registered.

Item 3

a supply that is made to a recipient who is not in Australia when the thing supplied is done and the effective use or enjoyment of which takes place outside Australia (other than a supply directly connected with goods situated in Australia when the thing supplied is done, or with real property situated in Australia).

Indirect Tax Legislation Amendment Bill 2000 proposes to amend item 3 of subsection 38-190(1) so that a supply will be GST-free if:

(a)

the supply is made to a recipient who is not in Australia when the thing supplied is done; and

(b)

the effective use or enjoyment of which takes place outside Australia;

other than a supply of work physically performed on goods situated in Australia when the thing supplied is done, or a supply directly connected with real property situated in Australia.

Item 4

a supply that is made in relation to rights if the rights are for use outside Australia or the supply is to an entity that is not an Australian resident and is outside Australia when the thing supplied is done.

Item 5

a supply that is constituted by the repair, renovation, modification or treatment of goods from outside Australia whose destination is outside Australia.

24. Under subsection 38-190(2), a supply listed as GST-free in subsection 38-190(1) is not GST-free if it is the supply of a right or option to acquire something the supply of which would be connected with Australia. For example, an Australian vehicle rental firm supplies car rental rights to a UK travel agency. The travel agency supplies car rental vouchers to UK tourists who may use the vouchers to obtain car rental in Australia. The supply of the car rental to the tourists is a supply that is connected with Australia. The supply of car rental rights to the UK travel agency is, therefore, not GST-free.

Indirect Tax Legislation Amendment Bill 2000 proposes to amend subsection 38-190(2) to clarify that this subsection does not apply where the supply underlying the right would be GST-free.

25. Under subsection 38-190(3) a supply covered by item 2 in subsection 38-190(1) is not GST-free if:

(a)

it is a supply under an agreement entered into, whether directly or indirectly, with a non - resident ; and

(b)

the supply is provided, or the agreement requires it to be provided, to another entity in Australia.

Example 4 - A supply covered by item 2 of subsection 38-190(1) and subsection 38-190(3)

26. A school in Australia provides tuition to overseas students in Australia. However, it bills the overseas parents of the students directly. As the supply is being made to the students in Australia the supply is not GST-free under item 2 in subsection 38-190(1).

Indirect Tax Legislation Amendment Bill 2000 proposes to introduce a new subsection 38-190(4). Subsection 38-190(4) will apply so that a supply covered by item 3 in subsection 38-190(1) is taken to be a supply made to a recipient who is not in Australia if:

(a)

it is a supply under an agreement entered into, whether directly or indirectly, with an Australian resident; and

(b)

the supply is provided, or the agreement requires it to be provided, to another entity outside Australia.

An example of the type of supply to be covered is a supply to an Australian business of a training course to be conducted overseas.

Importations

27. The importation of goods into Australia may be a 'taxable importation' and subject to GST.^[F10] The importation of things other than goods, that are supplied from overseas for use in Australia (and are, therefore, in that sense 'imported') are not taxable importations. However, the importation of things other than goods or real property may be subject to GST because of the operation of Division 84 (refer paragraphs 35 to 42 below).

Taxable importations

28. If you make an importation of goods into Australia, you must pay GST on that importation but only if that importation is a 'taxable importation.^[F11]

29. Under subsection 13-5(1) you make a 'taxable importation' if:

(a)

goods are imported; and

(b)

you enter the goods for home consumption (within the meaning of the Customs Act 1901).

However, the importation is not a taxable importation to the extent that it is a non-taxable importation.^[F12]

30. An importation of goods into Australia does not include an importation of money.^[F13]

31. If you make a 'creditable importation'^[F14] you are entitled to an input tax credit for that importation.^[F15]

32. Under section 15-5, you make a 'creditable importation' if:

(a)

you import goods solely or partly for a creditable purpose; and

(b)

the importation is a taxable importation; and

(c)

you are registered, or required to be registered.

33. You import goods for a creditable purpose to the extent that you import the goods in carrying on your enterprise.^[F16] However, you do not import goods for a creditable purpose to the extent that the importation relates to making supplies that would be input taxed or the importation is of a private or domestic nature.^[F17]

Taxable supply and taxable importation

34. Generally, a taxable importation is distinguishable from a taxable supply. However, sometimes a supplier may make a supply that gives rise to both a taxable importation and a taxable supply. This is explained in the Explanations section at paragraphs 152 to 162 below.

Offshore supplies other than goods or real property

35. If the supply of a thing other than goods or real property, is not connected with Australia the supply may, under section 84-5, be treated as a taxable supply subject to GST, if:

(a)

the recipient of the supply acquires the thing supplied solely or partly for the purpose of an enterprise that the recipient carries on in Australia, but not solely for a creditable purpose (paragraph 84-5(1)(a)); and

(b)

the supply is for consideration (paragraph 84-5(1)(b)); and

(c)

the recipient is registered, or required to be registered (paragraph 84-5(1)(c)).

However the supply is not a taxable supply to the extent that it is GST-free or input taxed.^[F18]

36. Under subsection 11-15(2) you do not acquire a thing for a creditable purpose to the extent that the acquisition relates to making supplies that would be input taxed or the acquisition is of a private or domestic nature.^[F19]

37. Thus if the acquisition of the thing (other than goods or real property) by the recipient relates to making supplies that would be input taxed or the acquisition is partly of a private or domestic nature, the supply is treated under Division 84 as a taxable supply.

38. If the recipient acquires the thing solely for a creditable purpose it is not a taxable supply under section 84-5. This is because if you acquire the thing solely for a creditable purpose and the supply is a taxable supply, you are entitled to an input tax credit equal to the GST payable on that supply.

39. The GST on a supply that is treated as a taxable supply under section 84-5 is payable by the recipient of the supply and is not payable by the supplier.^[F20] The charge for GST is reversed, hence this Division is commonly referred to as a 'reverse charge' provision.

Example 5 - The importation of things other than goods or real property to which Division 84 applies

40. Invest Bank, an Australian financial institution, engages Legal UK, solicitors operating in the UK, to prepare an opinion on the legal aspects of a proposed joint venture banking operation in Australia with a subsidiary of a UK bank. The legal advice is prepared in the UK and provided to Invest Bank in Australia. Under subsection 9-25(5) the supply of that advice is not connected with Australia because the advice is not prepared in Australia and Legal UK has no permanent establishment in Australia (refer paragraphs 175 to 224 of the Explanations section of the Ruling which explain the operation of subsection 9-25(5)).

41. In this example, we assume that the requirements of paragraphs 84-5(1)(b) and 84-5(1)(c) are satisfied. Invest Bank acquires the supply for the purpose of its enterprise carried on in Australia. By virtue of subsection 11-15(2), the acquisition made by Invest Bank is not solely for a creditable purpose because the acquisition relates to making supplies that are input taxed.^[F21] Thus the requirements of paragraph 84-5(1)(a) are satisfied and the supply by Legal UK is a taxable supply under section 84-5.

42. Under section 84-10 Invest Bank, the recipient of the supply, is liable to pay GST on the taxable supply.

Non-residents making supplies connected with Australia

43. Currently, non-resident enterprises that make supplies that are connected with Australia are required to register if the registration turnover threshold is met^[F22]. A non-resident enterprise is required to be registered if its annual turnover is at or above $50,000. The turnover threshold for a non-profit body is $100,000. Supplies that are not connected with Australia are disregarded in working out the annual turnover^[F23] Sometimes the requirements for non-resident enterprises to register pose practical difficulties when the non-resident has no presence in Australia.

However, Indirect Tax Legislation Amendment Bill 2000 proposes to introduce a new Division 83 which will provide that in certain circumstances, a non-resident supplier and an Australian recipient can agree that the GST payable on a taxable supply made by the non-resident supplier is payable by the Australian recipient. As these supplies are then disregarded in working out annual turnover, this may alleviate the need for the non-resident supplier to register.

Ruling

Supplies connected with Australia

Supplies of goods

44. A supply of goods is a supply of any form of tangible personal property, that is, any form of personal property that has a physical existence but does not include intangible personal property such as intellectual property like a copyright. A supply of goods can occur by way of sale, lease, hire etc.

Supplies of goods wholly within Australia

45. A supply of goods is connected with Australia if the goods are delivered, or made available, in Australia to the recipient of the supply (subsection 9-25(1)). If goods are delivered or made available in Australia to the recipient of the supply, the supply of goods is wholly within Australia.

46. In the context of subsection 9-25(1), goods are delivered in Australia if the goods are physically delivered in Australia. Goods are made available in Australia if the goods are physically made available in Australia.

47. Goods which are delivered or made available in Australia to the recipient may be goods that the supplier has acquired domestically or imported (see the example at paragraph 124 of the Explanations section).

48. Also, an overseas supplier may make a supply of goods that is wholly within Australia. For example, an overseas supplier may acquire goods in Australia and supply those goods to a recipient in Australia.

49. Where the recipient imports the goods into Australia, the supply of goods is not connected with Australia under subsection 9-25(1) because the goods are not delivered, or made available, in Australia to the recipient of the supply.

Supplies of goods from Australia

50. A supply of goods is connected with Australia, if the supply involves those goods being removed from Australia (subsection 9-25(2)). Removal of goods from Australia is a supply from Australia.

51. Goods removed from Australia means the goods are physically taken out of Australia.

Supplies of goods to Australia

52. A supply of goods is connected with Australia if the supply involves those goods being brought to Australia and the supplier either imports the goods into Australia (paragraph 9-25(3)(a)) or installs or assembles the goods in Australia (paragraph 9-25(3)(b)). The import of the goods into Australia or the installation or assembly of the goods in Australia is a supply of goods to Australia.

53. This means that the supplier is either an exporter from outside Australia and importer into Australia, or an exporter from outside Australia and installer or assembler in Australia.

54. Paragraph 9-25(3)(a) does not apply to a supply of goods that involves goods being brought to Australia where the recipient imports the goods into Australia.^[F24]

55. Under paragraph 9-25(3)(a) a supply of goods brought to Australia is connected with Australia if the supplier imports the goods regardless of whether or not the supplier engages a Customs broker to arrange customs clearance of the goods.

56. A supply that is connected with Australia under paragraph 9-25(3)(a) may give rise to a taxable supply and a taxable importation where the supplier imports the goods into Australia.

Supplies of real property

57. Real property is defined to include:

(a)

any interest in or right over land; or

(b)

a personal right to call for or be granted any interest in or right over land; or

(c)

a licence to occupy land or any other contractual right exercisable over or in relation to land.^[F25]

58. A supply of real property is connected with Australia if the real property, or the land to which the real property relates, is in Australia (subsection 9-25(4)). Land in this context means the physical land.

59. The reference in subsection 9-25(4) to 'land to which the real property relates' means that an interest in, or right over land is connected with Australia if the physical land to which the interest or right over it relates, is in Australia.

60. A supply of real property is connected with Australia if it involves, for example:

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the sale of land situated in Australia; or

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the grant, assignment or surrender of any interest in or right over land in Australia - e.g., a lease of land; or

*

a personal right to call for or be granted any interest or right over land in Australia; or

*

a licence to occupy land in Australia; or

*

any other contractual right exercisable over or in relation to land in Australia.

Supplies of anything else

61. A supply of anything other than goods or real property is connected with Australia if either:

(a)

the thing is done in Australia (paragraph 9-25(5)(a)); or

(b)

the supplier makes the supply through an enterprise that the supplier carries on in Australia (paragraph 9-25(5)(b)).

Thing is done in Australia

62. Thing is defined to mean anything that can be supplied or imported such as a service, advice, information or a right.^[F26] It is the subject of the supply.

63. Under paragraph 9-25(5)(a) the connection with Australia requires that the 'thing' being supplied is 'done' in Australia.

64. The meaning of 'done' depends on the nature of the 'thing' being supplied. 'Done' can mean, for example, performed, executed, completed, finished etc depending on what is supplied.

Supply of a service

65. If the 'thing' being supplied is a service, the supply of that service is typically done where the service is performed. If the service is performed in Australia, the service is done in Australia and the supply of that service is connected with Australia under paragraph 9-25(5)(a). This is the case even if the recipient of the supply is outside Australia.

66. However, the supply of a service to an offshore recipient may be GST-free under section 38-190. That section is outlined at paragraphs 23 to 26 above.

67. Under subsection 38-190(1) a service may be GST-free if:

Item 1

the service is directly connected with goods or real property situated outside Australia; or

Item 2

the services are provided to a recipient who is not an Australian resident and who is not in Australia when the thing supplied is done, that is, when the service is performed. The service must not be directly connected with goods situated in Australia when the service is performed or with real property situated in Australia; or

Indirect Tax Legislation Amendment Bill 2000, proposes to amend item 2 of subsection 38-190(1) so that a supply of services will be GST-free if the services are provided to a non-resident who is not in Australia when the thing supplied is done and:

(a)

the supply is neither a supply of work physically performed on goods situated in Australia when the work is done nor a supply directly connected with real property situated in Australia; or

(b)

the non-resident acquires the service in carrying on the non-resident's enterprise, but is not registered or required to be registered.

Item 3

the services are provided to a recipient who is not in Australia when the thing supplied is done, that is, when the services are performed and the services are to be used or enjoyed outside Australia. Again, the service must not be directly connected with goods situated in Australia when the service is performed or with real property situated in Australia.

Indirect Tax Legislation Amendment Bill 2000 proposes to amend item 3 of subsection 38-190(1) so that a supply of services will be GST-free if:

(a)

the services are provided to a recipient who is not in Australia when the thing is done, that is, when the services are performed; and

(b)

the services are to be used or enjoyed outside Australia.

The service must not be of work physically performed on goods situated in Australia when the thing supplied is done, that is, when the services are performed. The supply must not be directly connected with real property situated in Australia.

68. For the purposes of items 2 and 3 in subsection 38-190(1) of both the current law and the proposed amendments (items 2 and 3 are discussed in paragraph 67(ii) and (iii) respectively), the pre-condition that the recipient is not in Australia at the relevant time requires that neither the recipient, nor a representative acting on behalf of the recipient if the recipient is a company, is in Australia in relation to the supply.

69. Sometimes a service may involve both work being done and the creation of a product for the recipient However, this does not alter the nature of the supply as one for the performance of a service.

70. For example, if an architect is engaged to prepare and provide a plan for the recipient, the plan is the product produced as a result of the services provided by the architect. The service is done where the work is done, that is, where the plan is prepared or drawn. This is the case even if the contract is to deliver a completed plan. If the plan is prepared in Australia, the service is performed in Australia and the supply is connected with Australia. The delivery of the plan does not determine where the service is done. The product of that service, the plan, is not a separate supply from the supply of that service.

Provision of advice or information

71. If a supply is the provision of advice or information and the supply involves work to create, develop or produce that information or advice for the recipient, the supply is one of the performance of services. The advice or information is done where it is prepared, produced, or created, as the case may be. The supply of that advice or information is connected with Australia if the advice or information is prepared, created or produced in Australia.

72. For example, if a lawyer prepares a legal opinion in Australia and provides that opinion to an offshore recipient, the provision of that opinion is connected with Australia because the opinion is prepared in Australia. The provision of advice or information in cases of this kind is akin to the provision of a service which is done where the service is performed. Again, delivery of the end product is not relevant. The supply may be GST-free under subsection 38-190(1).

Instantaneous supply of advice or information

73. If the provision of advice or information is an instantaneous supply of advice or information, that advice or information is done where the advice or information is provided. The meaning of provided will depend on the facts in any given case. For example, if a client rings his or her accountant to obtain advice on an urgent matter and the accountant responds there and then over the phone, the advice is done where it is provided by the accountant. Again, depending on the circumstances, the supply may be GST-free under subsection 38-190(1).

The creation, grant, transfer, assignment or surrender of a right

74. If the supply is the creation, grant, transfer, assignment or surrender of a right, the creation of that right in another, the granting, transfer or assignment of that right to another, or the surrender of that right, is done where the right is created in that other person, granted, transferred or assigned to that other person or surrendered respectively.

75. The act that creates that right in another or grants, transfers or assigns that right to another, or surrenders the right, will depend on the facts of each individual case.

76. If, for example, a right is granted under an agreement to another to use certain intellectual property, the granting of that right to another is done where the agreement is made. If the agreement is made^[F27] in Australia, the supply of that right is connected with Australia. If the agreement is made outside Australia, the supply is not connected with Australia under paragraph 9-25(5)(a). However, even if the agreement is made outside Australia the supply is connected with Australia under paragraph 9-25(5)(b) if the supplier makes the supply through an enterprise that the supplier carries on in Australia (refer paragraphs 78 to 89 below).

Entry into, or release from, an obligation

77. If the supply is the entry into, or release from, an obligation to do anything, or to refrain from an act, or to tolerate an act or situation, the entering into that obligation or the release from that obligation is done where the obligation is entered into or the release is effected.

The supply is made through an enterprise carried on in Australia

78. If a supply of a thing is not connected with Australia because the thing is not done in Australia, the supply is connected with Australia if, under paragraph 9-25(5)(b), the supplier makes the supply through an enterprise that the supplier carries on in Australia.

79. The concept of carrying on an enterprise in Australia is defined in terms of the definition of 'permanent establishment' in subsection 6(1) of the Income Tax Assessment Act 1936.

80. Specifically, under subsection 9-25(6) the supplier carries on an enterprise in Australia if the enterprise is carried on through:

(a)

a permanent establishment (as defined in subsection 6(1) of the Income Tax Assessment Act 1936); or

(b)

a place that would be such a permanent establishment if paragraph (e), (f) or (g) of that definition did not apply.

81. An enterprise is defined in section 9-20 (see the definitions section of the Ruling at paragraph 238). Broadly speaking, an enterprise is an activity, or series of activities done in a particular manner. For example, an enterprise is an activity, or series of activities, done in the form of a business.^[F28]

82. Carrying on an enterprise includes doing anything in the course of the commencement or termination of the enterprise.^[F29]

References