TAXATION RULING NO. ST 2114

ST 2114

SALES TAX : DOMESTIC SATELLITE RECEIVING EQUIPMENT

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FOI status:

May be releasedFOI number: I 1131988

FACTS

Domestic satellite receiving systems are designed to provide T.V. reception on ordinary television sets in remote areas where normal television reception is not possible. T.V programmes are beamed to a satellite which transmits them back to earth receiving stations located in remote areas. The signals are processed by the stations into a form capable of being received by a normal T.V. set.

2. The usual components of the systems include a reflector panel or screen, the collector horn, low noise amplifier, frequency converter and receiver/converter. The reflector panel/screen which is located outdoors picks up the microwave signals from the satellite and reflects them to the collector horn, positioned adjacent to the panel, which receives the signal and feeds it to the low noise amplifier which, in turn, amplifies the signal and filters out static noise. The frequency converter alters the microwave signal to super high frequency (SHF). A coaxial cable leads the SHF signal to the receiver/converter located either on top of or near to a T.V. set which changes the SHF signal to a very high frequency (VHF) signal suitable for television reception. The receiver/converter functions as a demodulator and can also be used as a tuner where there is more than one signal.

RULING

3. The various components of the system are classified separately according to their function.

4. The reflector panel or screen, collector horn, low noise amplifier and frequency converter are within themselves segments of a receiving system and not accessories to a television set. The collector horn, low noise amplifier and frequency converter are taxable at the general rate which currently is 20%.

5. The reflector panel or screen is generally not provided as a single item but as a number of component parts which are joined together on installation. The panel or screen becomes a fixture and is not goods. The various components of the panel or screen are classified separately. Most of the components are exempt from tax under items 82A (building piping or tubing), 84(1) (metal building materials) or 86(1) (metal materials).

6. In some cases the reflector panel antenna has been replaced by a parabolic dish antenna which consists of the dish and a support frame. The kit consists of a central circular dish and ten prefabricated fibreglass petals which have been impregnated with a metallic substance to give it reflective properties. The petals are bolted together around the central dish during assembly on site. The dish and petals are not covered by item 84(1), First Schedule, but are taxable at the general rate.

7. The receiver/converted (demodulator) is an auxiliary to a television set and covered by item 48, Second Schedule, and taxable at 32.5%. Item 48 specifically mentions demodulators. The receiver/converter is also considered to be an accessory to a television set and covered by item 50, Second Schedule. This does not affect the classification of the receiver/converter because goods covered by item 50 are also taxable at 32.5%.

COMMISSIONER OF TAXATION
25 February 1985

References

ATO references:
NO 84/4986-4

Related Rulings/Determinations:

ST 2119

Subject References:
DOMESTIC SATELLITE
RECEIVING EQUIPMENT

Legislative References:
SALES TAX (EXEMPTIONS AND CLASSIFICATIONS) ACT 1935 SUB-ITEMS 18(1)
84(1)
84(2)
86(1) FIRST SCHEDULE,
ITEMS 48,
50, SECOND SCHEDULE