Goods and Services Tax Ruling

GSTR 2002/2A11 - Addendum

Goods and services tax: GST treatment of financial supplies and related supplies and acquisitions

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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 2002/2 to:

•

make minor consequential updates to the definition of 'ATM' as part of the updates to Goods and Services Tax Ruling GSTR 2014/2 Goods and services tax: treatment of ATM service fees, credit card surcharges and debit card surcharges, to reflect the decision in Banktech Group Pty Ltd v Commissioner of Taxation [2023] AATA 3850

•

ensure currency of legislative and other citations

•

make editorial changes where required to meet accessibility requirements.

GSTR 2002/2 is amended as follows:

1. Paragraph 1

In footnote A1, after the first sentence, insert 'The'.

2. Paragraph 22

Omit 'provision and/or disposal'; substitute 'provision or disposal'.

3. Paragraph 26

In footnote 22A, omit 'subsection 40-5.09(4A)'; substitute 'subsection 40-5.09(5)'.

4. Paragraph 80A

(a) In footnote 38B, omit '(2010) 187 FCR 398; '.

(b) Omit the wording of the quote; substitute:

145. Although the subject matter in Yanner is very different indeed from that in these appeals, the discussion about the concept of "property" is helpful in the present context. First, Yanner shows that the meaning of the word "property" can be fixed by relevant context, and the rather narrow meanings given in the authorities cited by the respondents will not apply in all contexts. Secondly, the word "property" can be applied to different kinds of relationships between a person and a subject matter, and can be understood as referring to the degree of power that is recognised in law as power permissibly exercised over the thing.

146. Considering the text of the GST Act (especially ss 9-10 and 11-10) and the Regulations, it is apparent that the term "interest" is referable to a very broad conception of property. The words "anything" and "in any form" in regulation in 40-5.02 highlight this extensive scope. Further, as the Commissioner submitted, the examples of financial supplies in the table in regulation 40-5.09(3) include a range of items that would not fit the narrower definition of property urged by the respondents. The same can be said of the "examples of interest" attached to regulation 40-5.02. These examples are illustrative of the proposition in the joint judgment in Yanner mentioned above.

5. Paragraph 81

(a) Omit the wording of the quote; substitute:

It may be said categorically that alienability is not an indispensable attribute of a right of property according to the general sense which the word "property" bears in the law. Rights may be incapable of assignment, either because assignment is considered incompatible with their nature, as was the case originally with debts (subject to an exception in favour of the King) or because a statute so provides or considerations of public policy so require, as is the case with some salaries and pensions; yet they are all within the conception of "property" as the word is normally understood...

(b) After 'the purposes of Part IIIA of the ITAA', insert '1936'.

6. Paragraph 84

Omit dot points 4 to 10; substitute:

•

specified superannuation arrangements (table item 4 of subsection 40-5.09(3));

•

an annuity or allocated pension (table item 5 of subsection 40-5.09(3));

•

specified life insurance business or related reinsurance business (table item 6 of subsection 40-5.09(3));

•

a guarantee (table item 7 of subsection 40-5.09(3));

•

an indemnity (table item 7A of subsection 40-5.09(3));

•

credit under a hire purchase agreement entered into before 1 July 201243A (table item 8 of subsection 40-5.09(3));

•

Australian currency, currency of a foreign country, digital currency or an agreement to buy or sell any of these three things (table item 9 of subsection 40-5.09(3));

7. Paragraph 94

Omit 'can not'; substitute 'cannot'.

8. Paragraph 113

After 'are satisfied', insert a comma.

9. Paragraph 159

Omit both instances of 'P/L'; substitute 'Pty Ltd'.

10. Paragraph 171A

In footnote 69AAAA, omit 'subsection84-(2)'; substitute 'subsection 84-5(2)'.

11. Paragraph 185

Omit the dot points; substitute:

•

supplies of cheque and deposit forms to an ADI and special forms provided to account holders (table items 1 and 2 of section 40-5.12);

•

professional services, including information and advice in relation to a financial supply (table item 3 of section 40-5.12);

•

an interest in or under a payment system (table item 4 of section 40-5.12);

•

stored value cards not linked to an account with an ADI (table item 5 of section 40-5.12);

•

goods supplied in accordance with agreements under which the goods are leased, where the lessors dispose of their rights in the goods to the lessees, or the lessees have no obligation or option to acquire the rights of the lessors in the goods (table item 6 of section 40-5.12);

•

an option, right or obligation to make a taxable supply or acquire something the supply of which is a taxable supply, except a mortgage or charge mentioned in table item 3 of subsection 40-5.09(3) (table item 7 of section 40-5.12);

•

a supply made as a result of the exercise of an option or right, or the performance of an obligation to make a taxable supply or acquire something the supply of which is a taxable supply (table item 8 of section 40-5.12);

•

facilities for trading securities or derivatives and clearance and settlement of those trades (table item 9 of section 40-5.12);

•

insurance and reinsurance business (other than life insurance business) (table item 10 of section 40-5.12);

•

broking services (table item 11 of section 40-5.12);

•

management of the assets or liabilities of another entity (table item 12 of section 40-5.12);

•

debt collection services (table item 13 of section 40-5.12);

•

sales accounting services under a factoring arrangement (table item 14 of section 40-5.12);

•

trustee services (table item 15 of section 40-5.12);

•

custodian services in relation to money, digital currency, documents and other things (table item 16 of section 40-5.12);

•

currency with a market value that exceeds its stated value as legal tender (table item 17 of section 40-5.12);

•

bailment and floorplan arrangements (table item 18 of section 40-5.12);

•

goods supplied under a hire purchase agreement entered into on or after 1 July 2012 (table item 19 of section 40-5.12);

•

credit under a hire purchase agreement entered into on or after 1 July 2012 (table item 20 of section 40-5.12); and

•

a warranty for goods (table item 21 of section 40-5.12).

12. Paragraph 187

After 'deposits the fund into Marrakesh', omit 'Holdings's'; substitute 'Holdings'.

13. Paragraph 193

Omit 'agent/principal'; substitute 'agent and principal'.

14. Paragraph 206

Omit 'reward/loyalty point'; substitute 'reward or loyalty point'.

15. Paragraph 216

(a) Omit Table 1, including caption and footnote 92; substitute:

(b) After Table 1, insert new Table 2 including caption:

(c) In the caption for new Table 2, after 'subsection 70-5.02A(3)', insert new footnote 91A:

^91A. The conditions of subsection 70-5A(2) must also be met before the acquisition is a reduced credit acquisition. See paragraphs 218 to 219 of this Ruling for an explanation.

16. Paragraph 255

(a) Omit 'table items of 24(h) and 26(h)'; substitute 'table items 24(h) and 26(h)'.

(b) Omit 'table items of 24 and 26'; substitute 'table items 24 and 26'.

17. Paragraph 257

Omit the heading; substitute 'What is a financial supply facilitator?'

18. Paragraph 285

(a) Omit 'Transaction Banking & Cash Management'; substitute 'Transaction Banking and Cash Management'.

(b) Omit 'Inventory/receivables finance'; substitute 'Inventory or receivables finance'.

19. Paragraph 287

Omit the wording of the paragraph, including the table; substitute:

This is represented in Table 3 of this Ruling:

Table 3: Requirements for a financial supply in the Accounts table in Schedule 2 of this Ruling

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A2	Account opening, keeping, maintenance and service fees	40-5.09(3) Table item 1	Input taxed	Subsection 40-5.09(4) may also apply

20. Paragraph 288A

In the second sentence, omit 'subsection 38-190(1)'; substitute 'subsection 38-190(1)'.

21. Paragraph 292

Omit the wording of the paragraph including the table; substitute:

This is represented in Table 4 of this Ruling:

Table 4: Incidental financial supplies in the Loan Transactions table in Schedule 2 of this Ruling

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
B48	Card insurance (supplied with card – no separate fee)	40-5.09(3) Table item 1 and 2 and 40-5.10	Input taxed	Not applicable

22. Paragraph 295

Omit the wording of the paragraph, including the table; substitute:

This is represented in Table 5 of this Ruling:

Table 5: Requirements for a non-financial supply in the Fees and charges payable by a merchant for merchant operations table in Schedule 2 of this Ruling

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A102	Sales processed fee	Section 9-5 40-5.12 item 4	Taxable†	Not applicable

23. Glossary of terms

(a) Omit the wording of the entry for 'Abbreviations'; substitute:

Abbreviations

Table 6: Legislation used in this Glosary of Terms

Act Name	Abbreviation
Corporations Act 2001	Corporations Act
Superannuation Industry (Supervision) Act 1993	SIS Act
A New Tax System (Goods and Services Tax) Act 1999	GST Act
A New Tax System (Goods and Services Tax) Regulations 2019	GST Regulations
Income Tax Assessment Act 1936	ITAA 1936
Income Tax Assessment Act 1997	ITAA 1997

(b) Omit the wording of the entry for 'Account'; substitute:

For the purposes of table item 1 of subsection 40-5.09(3) and subsection 40-5.09(4), account means an account made available by an Australian ADI within the meaning of section 9 of the Corporations Act. For these purposes, it includes the following accounts:

•

savings or transaction accounts (including accounts linked to debit cards);

•

cheque accounts;

•

call accounts;

•

retirement savings accounts;

•

term deposits;

•

loan accounts; and

•

credit card accounts.

For the purposes of section 70-5.02, the meaning of account is not limited to Australian ADIs but extends to accounts provided by non-ADIs, as explained at paragraphs 202 to 206 of this Ruling.

It includes an account in relation to which the account holder (the customer) has the right to:

•

have the account maintained by the account provider (the provider);

•

repayment of the amount credited to the account by the provider; and

•

require the provider to act on directions by the customer that are in accordance with the arrangements, or any agreement, between the provider and the customer in relation to operation of the account.

The definition of account in the GST regulations does not extend to an 'account' that records non-monetary balances such as reward or loyalty point and 'frequent flyer' point balances.

(c) Under the entry for 'Allocated Pension/ Annuity':

(i)

omit the heading; substitute 'Allocated Pension or Annuity'.

(ii)

omit all instances of pension/annuity; substitute 'pension or annuity'.

(d) Under the entry for 'Assurance', omit 'life assurance/life insurance'; substitute 'life assurance or life insurance'.

(e) Omit the wording of the entry for 'Automatic Teller Machine (ATM)'; substitute:

ATM

The term 'ATM' or 'automatic teller machine' has its ordinary meaning, as set out in Goods and Services Tax Ruling GSTR 2014/2 Goods and services tax: treatment of ATM service fees, credit card surcharges and debit card surcharges.

(f) Under the entry for 'CHAMP', omit 'Australian Stock Exchange's'; substitute 'Australian Securities Exchange's'.

(g) Omit the wording of the entry for 'Clearing House Electronic Subregister System (CHESS)'; substitute:

Clearing House Electronic Sub-register System (CHESS)

A clearing and settlement system for equities involving the Australian Securities Exchange and the banking system. It provides for electronic transfer of title to securities and electronic payment rather than payment by cheque. Settlement for transactions between brokers must take place on the third business day after the date of the transaction (T+3).

(h) Under the entry for 'Debt Security', omit 'Australian Stock Exchange'; substitute 'Australian Securities Exchange'.

(i) Under the entry for 'Equity Security', omit 'Australian Stock Exchange'; substitute 'Australian Securities Exchange'.

(j) Omit the heading for the entry 'Floor Plan Arrangement/Finance'; substitute 'Floor Plan Arrangement or Finance'.

(k) Under the entry for 'Forfaiting', omit 'nonrecourse'; substitute 'non-recourse'.

(l) Omit the wording of the entry for 'Income Commission'; substitute:

Income Commission

Commission based fees calculated on the income derived from assets held, managed, or both, on behalf of another.

(m) Omit the wording of the entry for 'Interchange Fees'; substitute:

Interchange Fees

Payments and associated fees between participants in a payment system to cover operating costs and risks associated with Interchange.

(n) Under the entry for 'Investment Account Contract' and 'Investment-Linked Contract', omit 'death or on a specified date(s)'; substitute 'death or on a specified date or dates'.

(o) Under the entry for 'Loyalty Program':

(i)

omit 'customers to be loyal to the supplier(s)'; substitute 'customers to be loyal to the supplier or suppliers'

(ii)

omit 'require an application fee and/or annual fees'; substitute 'require an application fee or annual fees, or both'.

(p) Under the entry for 'Macroeconomics', omit 'GDP'; substitute 'gross domestic product'.

(q) Under the entry for 'Management Fee', omit all instances of 'manager(s)'; substitute 'managers'.

(r) Under the entry for 'Master Fund', omit 'underlying investment product(s)'; substitute 'underlying investment product or products'.

(s) Under the entry for 'Merchant', omit 'supplies goods and/or services'; substitute 'supplies goods, services or both'.

(t) Omit the heading for the entry 'Night Safe/Wallet'; substitute 'Night Safe or Wallet'.

(u) Under the entry for 'Prospectus', omit 'Australian Securities & Investments Commission'; substitute 'Australian Securities and Investments Commission'.

(v) Under the entry for 'Securities':

(i)

omit 'section 92(1) of the Corporations Act'; substitute 'subsection 92(1) of the Corporations Act'.

(ii)

after 'interests in a managed investment scheme; or' insert ellipsis on a new line

(iii)

after 'units of such share;', insert ellipsis on a new line.

(w) Under the entry for 'Settlement', after 'that is', insert a comma.

(x) Under the entry for 'Stored Value Card':

(i)

omit 'additional dollars/points'; substitute 'additional dollars or points'.

(ii)

omit 'and/or PIN'; substitute ', PIN or both'.

(y) Under the entry for 'Trailing Commission', omit 'investment and/or continued investment'; substitute 'investment or continued investment'.

(z) Under the entry for 'Trust Deed', omit 'trustee(s)'; substitute 'trustee or trustees,'.

24. Schedule 2 – Table of Contents

Omit the Table of Contents; substitute:

25. SCHEDULE 2 – supplies of financial interests and related supplies by financial supply providers ^§ and financial supply facilitators ^§

(a) Omit the wording from the References text box; substitute:

References

The tables below use the following style of abbreviations

"9-5" – means section 9-5 of the GST Act

"40-5.09" – means section 40-5.09

"40-5.09(3)" – means subsection 40-5.09(3)

"40-5.09(3) Item 1" – means Item 1 of subsection 40-5.09(3)

"40-5.12 Items 1 and 2" – means Items 1 and 2 of section 40-5.12

"40-5.09(4)" – means subsection 40-5.09(4)

"70-5.02(2) Item 6(c)" – means Item 6(c) of subsection 70-5.02(1)

(b) Omit the wording from the Notes text box; substitute:

Notes

1.

Fees, charges and payments received or charged for a supply are generally regarded as consideration (or part of the consideration) for a financial supply rather than a financial supply themselves. For example, interest payable on money loaned or deposited is generally regarded as part of the consideration for the use of money (a debt).

In this table the listed fees, charges and payments are given a GST status which technically corresponds to the supply for which they are given as consideration. For example, fees paid as part of the consideration for a loan are categorised as 'input taxed'. Where consideration is listed in the second column, the item (or legislative provision) that relates to it is listed in the third column.

2.

Some supplies (fees, charges, etcetera) may be covered by more than one item. The fact a supply appears under a particular heading in this Schedule does not mean that it cannot also be covered by another item, however that does not make it more than one supply. The fact something is not mentioned as being covered by an item does not mean that it is not or cannot be covered by that item.

3.

The supply of something is not a financial supply if it does not satisfy the requirements of section 40-5.09 or if it is mentioned within an item in section 40-5.12. Where this is the case, the table contains a reference to the relevant item in the GST regulations as well as the provision in the GST Act (if any) that determines its GST status. Items of this kind in the table are identified by the symbol "†".

4.

If something is said to be taxable, GST-free or input taxed, within column 4 of the table, it is assumed that the other conditions for a supply of that type are also met (for example, for a taxable supply, that the requirements of section 9-5 are able to be satisfied.) These items in the table are identified by the symbol "‡". The actual status will depend on all the facts and circumstances of the supply. Each transaction will need to be judged and its GST status determined by having regard to all the facts and circumstances particular to that case.

4A.

The fact that something is not specifically mentioned in Schedule 2 as being GST-free wholly or in part under subsection 38-190(1) does not mean it is not, or cannot be covered by that provision. Reference should be made to paragraph 288A of this Ruling.

5.

Any references to table item 1 of subsection 40-5.09(3) in column 3 of the table are only relevant to ADIs however most things covered by item 1 should apply (where relevant) to non-ADIs.

6.

Line numbers in column 1 are used for ease of reference to a particular item and have no legislative basis. The symbol "§" indicates that the term is defined in Schedule 1, which does not form part of the binding section of this Ruling.

26. Table A. Summary of fees and services – Transaction banking and cash management

(a) Omit the table, including the heading and footnote 114; substitute:

Summary of fees and services – Transaction banking and cash management

ACCOUNTS^§

The following fees and charges listed in Table A.1: ACCOUNTS, by Australian ADIs^§ as account provider to account holders, or by an ADI to a non-account holder for a fee of $1,000 or less.

Note: Where supplied to a non-account holder, the following conditions must also be met:

1.

item 1 in subsection 40-5.09(3) would have applied to that supply in relation to an account with the ADI; or

2.

the fee relates to an application to the ADI that, if accepted, would result in the creation of an account by the ADI.^113C

If the fee or charge is greater than $1,000, the supply is taxable unless listed elsewhere.

The extent to which the supply of a transaction account is GST-free under table item 3 or table item 4(a) of subsection 38-190(1) is explained in GSTD 2020/1.

Table A.1: ACCOUNTS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A2	Account opening, keeping, maintenance and service fees	40-5.09(3) Item 1	Input taxed	Not applicable
A3	Account application fees	40-5.09(3) Item 1 40-5.09(4)(b)	Input taxed	The fee charged is in relation to application and input taxed. Even if bank to bank, if fee is $1,000 or less, paragraph 40-5.09(4)(b) will apply.
A4	Transaction fees	40-5.09(3) Item 1	Input taxed	Not applicable
A5	Fees and charges for account transactions by ATM§, telephone or other electronic means	40-5.09(3) Item 1	Input taxed	Not applicable
A6	Fees and charges for account transactions performed by accessing Internet banking services	40-5.09(3) Item 1	Input taxed	Transactions must be in relation to an account with the ADI. Payment to a third party to provide a link to the Internet site of the ADI will be a separate (taxable) supply because the third party is not a financial supply provider§.
A7	Enquiry or account information fees	40-5.09(3) Item 1	Input taxed	Not applicable
A8	Closure of account fee	40-5.09(3) Item 1	Input taxed	Not applicable
A9	Preparation, reconciliation and replacement of account statement or duplicate statement	40-5.09(3) Item 1	Input taxed	Not applicable
A10	Photocopies and facsimiles of account information	40-5.09(3) Item 1	Input taxed	Not applicable
A11	Confirmation of account or accounts fee	40-5.09(3) Item 1	Input taxed	Not applicable
A12	Deposit§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A13	Deposit§ splitting fees (money§ deposited is "split" and credited to a number of different accounts held by the same account holder)	40-5.09(3) Item 1	Input taxed	Not applicable
A14	Withdrawal§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A15	Excess withdrawal§ fee	40-5.09(3) Item 1	Input taxed	Not applicable
A16	Balance below minimum fees	40-5.09(3) Item 1	Input taxed	Not applicable
A17	Direct debit§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A18	Dishonoured direct debit§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A19	Stopped payment fees	40-5.09(3) Item 1	Input taxed	Not applicable
A20	Set-off§ fees	40-5.09(3) Item 1	Input taxed	Not applicable

Table A.2: PASSBOOKS^§ AND TRANSACTION CARDS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A21	Fees for issue and replacement of passbook	40-5.09(3) Item 1	Input taxed	Not applicable
A22	Fees for issue and replacement of transaction card and PIN§	40-5.09(3) Item 1	Input taxed	Not applicable
A23	Fees for issue and replacement of debit, credit, charge and smart cards§	40-5.09(3) Item 1	Input taxed	Stored value cards§ not linked to accounts provided by an Australian ADI§ are not a financial supply§ under section 40-5.12 Item 5. See also Line Nos. A117 to A119 and B31 to B49.

Table A.3: CHEQUES^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A24	Fees for sales of standard cheque§ and deposit§ books	40-5.09(3) Item 1	Input taxed	Printing of special forms and overprinting of standard forms are not input taxed as they are covered under section 40-5.12 item 2.
A25	Fees for cheques§ deposited	40-5.09(3) Item 1	Input taxed	Not applicable
A26	Fees for post-dated cheques§ and clearing cheques§	40-5.09(3) Item 1	Input taxed	Not applicable
A27	Stopped cheque§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A28	Fees for early clearance of cheque§	40-5.09(3) Item 1	Input taxed	Not applicable
A29	Dishonoured cheque§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A30	Fees for cashing cheques§ and payment orders§	40-5.09(3) Item 1	Input taxed	Not applicable
A31	Fees for clearing bank cheques§	40-5.09(3) Items 1 and 10	Input taxed	A bank cheque§ is the provision of an interest in a security under subsection 40-5.09(3) Item 10; Schedule 2, clause 8, item 9 and definition of debenture§ in section 9 of the Corporations Act.
A32	Repurchase of bank cheque§	40-5.09(3) Items 1 and 10	Input taxed	A bank cheque§ is the provision of an interest in a security under subsection 40-5.09(3) Item 10; Schedule 2, clause 8, item 9 and definition of debenture§ in section 9 of the Corporations Act.
A33	Duplicate of bank cheque§ already issued	40-5.09(3) Items 1 and 10	Input taxed	Not applicable

Table A.4: VOUCHERS^§, DEPOSIT AND WITHDRAWAL SLIPS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A34	Information about deposit§ and withdrawal§ slips and credit or charge card§ vouchers§ used on account transactions	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
A35	Supply to customers of deposit§ books including those with identifying information (for example, real estate agents deposit§ book for tenant)	40-5.09(3) Item 1 40-5.12 Item 2	Input taxed	If section 40-5.12 item 2 applies, this overrides section 40-5.09.
A36	Reconciliation of deposit§ and withdrawal§ slips and credit or charge card§ vouchers§	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
A37	Retention and storage of deposit§ and withdrawal§ slips and credit or charge card§ vouchers§	40-5.09(3) Items 1 and 2	Input taxed	Not applicable

Table A.5: TRANSFERS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A38	Cash transfers, money orders§ and other forms of direct funds remittance	40-5.09(3) Item 1	Input taxed	Not applicable
A39	Electronic transfer to another Australian ADI	40-5.09(3) Item 1	Input taxed	Subsection 40-5.09(4) may also apply.
A40	International money§ transfer or telegraphic transfer§	40-5.09(3) Item 1	Input taxed	Where the transfer is undertaken as a transaction under the supply of a transaction account, GSTD 2020/1 will be relevant. A separate supply of an international money transfer or telegraphic transfer is GST-free under table item 4 of subsection 38-190(1) when the overseas payee has a right to payment that must be exercised at an overseas bank – whether it is via a deposit into the overseas payee's overseas account, or right to request payment at a bank located overseas.

Table A.6: OVERDRAFTS^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A41	Unauthorised overdraft§ fee	40-5.09(3) Item 1	Input taxed	Not applicable
A42	Overdraft§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A43	Maintenance of overdraft§ facility	40-5.09(3) Item 1	Input taxed	Not applicable

Table A.7: WALLETS OR NIGHTSAFES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A44	Supply and use of wallets for night safe	40-5.09(3) Item 1	Input taxed	Input taxed provided the contents in the wallet held by bank for safe custody§ and credited to the customer's account. If not credited to the customer's account the supply of wallet and key for this facility will be taxable as a custodian§ service under item 16, section 40-5.12.
A45	Alternative or additional key to night safe or wallet§	40-5.09(3) Item 1	Input taxed	Input taxed provided the contents in the wallet held by bank for safe custody§ and credited to the customer's account. If not credited to the customer's account the supply of wallet and key for this facility will be taxable as a custodian§ service under item 16, section 40-5.12.
A46	Fee for lost key to night safe or wallet§	40-5.09(3) Item 1	Input taxed	Input taxed provided the contents in the wallet held by bank for safe custody§ and credited to the customer's account. If not credited to the customer's account the supply of wallet and key for this facility will be taxable as a custodian§ service under item 16, section 40-5.12.
A47	Supply of permanent wallet	40-5.09(3) Item 1, 40-5.09(4)(a)	Input taxed	Input taxed provided the contents in the wallet held by bank for safe custody§ and credited to the customer's account. If not credited to the customer's account the supply of wallet and key for this facility will be taxable as a custodian§ service under item 16, section 40-5.12.

Table A.8: OTHER

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A48	Fee for negotiation§ of a clean bill§ of exchange§	40-5.09(3) Items 1 and 10	Input taxed	Not applicable
A49	Collection, handling and sorting of cash, and cheques§ (including lottery, art union proceeds, etcetera)	40-5.09(3) Item 1	Input taxed	Limited to those types of collection handling and sorting services generally provided to account holders by account providers in connection with an account. Where done for a non-account holder, and NOT in relation to a payment system§, it may also be input taxed, if subsection 40-5.09(4) is satisfied. Collection, handling and sorting done in relation to a payment system§ is taxable under item 4, section 40-5.12 even if fee charged is $1,000 or less.
A50	Changing cash into different cash denominations	40-5.09(3) Item 1	Input taxed	Not applicable
A51	Deposits to an account	No provision, acquisition or disposal of an interest	Not subject to GST	Not applicable
A52	Withdrawals from an account	No provision, acquisition or disposal of an interest	Not subject to GST	Not applicable
A53	Establishing, operating and terminating letters of credit	40-5.09(3) Items 2 and 10	Input taxed	Not applicable
A54	Fee for collecting interest payments under a debenture§ on behalf of an account holder	40-5.09(3) Item 1	Input taxed	Payment under a debenture§ may also be covered by items 2 and 10 of section 40-5.09.
A55	Sweep§ and zero balance facility§ fees	40-5.09(3) Item 1	Input taxed	Not applicable
A56	Garnishee§ of accounts	40-5.09(3) Item 1	Input taxed	Not applicable
A57	Nostro account§ (account held by Australian bank in foreign bank in foreign currency)	See note	Not subject to GST	The account is supplied by a foreign bank, outside Australia and does not satisfy section 40-5.09. See paragraph 30 of this Ruling.
A58	Vostro account§ (account held by foreign bank in Australian bank in Australian currency)	Subsection 38-190(1) Item 2	GST-free	Supply is GST-free subject to section 38-190. See paragraphs 144 to 169 of this Ruling.
A59	Audit certificates, letters of identification and bankers opinions in relation to application for an account	40-5.09(3) Item 1 40-5.09(4)(b)	Input taxed	Charge is in relation to application and input taxed. Even if bank to bank, if fee is $1,000 or less, paragraph 40-5.09(4)(b) will apply.
A60	Providing letter of identity to government statutory body (for example, Centrelink) for account holder	40-5.09(3) Item 1	Input taxed	Not applicable
A61	Recovery§ of Commonwealth, State and Territory fees, duties and taxes incurred in relation to an account	40-5.09(3) Item 1 Examples for item 1 in 40-5.09(3) as set out in Schedule 2, clause 1, Item 15	No supply where recovery§ Input taxed where on-charged.	See paragraphs 181-186 of the Ruling for a discussion.
A62	Disbursements on-charged to customers as account-related fees	40-5.09(3) Item 1	Input taxed	Not applicable

Table A.9: COMPUTER BANKING SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A64	Software licence fee (annual or once off)	Section 9-5	Taxable‡	Taxable not as a payment system§ but because service provided by the financial institution does not come within subsections 40-5.09 (3) or (4).
A65	Maintenance or software access fee (for maintenance and support services)	Section 9-5	Taxable‡	Taxable not as a payment system§ but because service provided by the financial institution does not come within subsections 40-5.09 (3) or (4).
A66	Support services (as and when required)	Section 9-5	Taxable‡	Taxable not as a payment system§ but because service provided by the financial institution does not come within subsections 40-5.09 (3) or (4).
A67	Fees for the reversal of amounts incorrectly deposited to an account (good value claims) and administration between financial institutions	40-5.09(3) Item 1	Input taxed	Not applicable
A68	Fees charged to customer for extra cost of special printing of special forms	Section 9-5 40-5.12 Item 2	Taxable†	Not applicable
A69	Fees charged to customer for extra cost of overprinting of standard forms	Section 9-5 40-5.12 Item 2	Taxable†	Not applicable
A70	Fees charged to customer for bulk bank cheque§ printing and production (bill paying service)	Section 9-5 40-5.12 Item 2	Taxable†	Not applicable
A71	Information about account or customer's dealing with bank under Subpoena§	Section 9-5	Taxable‡	In relation to third party and not connected with an account.
A72	Fee for access to secure packet or envelope in safe custody§ facility or in bank branch safe where contents are not credited to customer's account	Section 9-5 40-5.12 Item 16	Taxable†	The supply is taxable because item 16 of section 40-5.12 overrides subsection 40-5.09(4).

Table A.10: PAYMENT AND FUNDS TRANSFER

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A73	Fees and charges of $1,000 or less for a clearing account§ for use within a day (intra day facility) made available by an Australian ADI§ for non-account holders	40-5.09(4)(a)	Input taxed	Not applicable
A75	Operation and maintenance: transfers between accounts	40-5.09(3) Item 1	Input taxed	Account holders are not participants§ in a payment system§.
A76	Operation and maintenance: direct credits§	40-5.09(3) Item 1	Input taxed	Account holders are not participants§ in a payment system§.
A77	Operation and maintenance: direct debits§	40-5.09(3) Item 1	Input taxed	Account holders are not participants§ in a payment system§.
A78	Operation and maintenance: automatic and electronic funds transfers (such as telegraphic transfers§ and EFTPOS§)	40-5.09(3) Item 1	Input taxed	A separate supply of an international money transfer is GST-free under table item 4 of subsection 38-190(1) when the payee's account is located outside Australia or collection or delivery of physical currency is to an overseas location. Where the transfer is undertaken as a transaction under the supply of a transaction account, GSTD 2020/1 will be relevant.
A79	Use of ATM: fees charged by Australian ADIs§ to account holders for the use of an ATM	40-5.09(3) Item 1	Input taxed	Where the ATM transaction is undertaken as a transaction under an account, GSTD 2020/1 will be relevant to determining the extent to which the supply of the account may be GST-free.
A79A	Use of ATM: fees of $1,000 or less for the supply of ATM services mentioned in subsection 40-5.09(5) charged by an Australian ADI to a recipient who is not an account holder	40-5.09(5)	Input taxed	Not applicable
A79B	Use of ATM: fees of $1,000 or less for the supply of ATM services mentioned in subsection 40-5.09(5) charged by an entity that is not an Australian ADI	40-5.09(5)	Input taxed	Not applicable
A80	Fees and charges to an account holder for real time gross settlement (RTGS) §	40-5.09(3) Item 1	Input taxed	Access provided to an account provider in relation to an approved RTGS§ payment system§ is a taxable supply.
A81	Inward, outward clean collections§ (Collection of bills of exchange drawn on an Australian ADI§ by an overseas party)	40-5.09(3) Item 1	Input taxed	Not applicable
A83	Fees charged by a financial supply facilitator§ to an account provider for processing, settling, clearing§ and switching transactions (in relation to a payment system§) for : charge, credit and debit card§ transactions	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A84	Fees charged by a financial supply facilitator§ to an account provider for processing, settling, clearing§ and switching transactions (in relation to a payment system§) for : cheque§ transactions	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A85	Fees charged by a financial supply facilitator§ to an account provider for processing, settling, clearing§ and switching transactions (in relation to a payment system§) for: internet banking	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A86	Fees charged by a financial supply facilitator§ to an account provider for processing, settling, clearing§ and switching transactions (in relation to a payment system§) for: Bank@Post§	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A87	Fees charged by a financial supply facilitator§ to an account provider for processing, settling, clearing§ and switching transactions (in relation to a payment system§) for : SWIFT§ (Society for Worldwide Interbank Financial Telecommunications Payment Delivery System)	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A88	Fees charged by a financial supply facilitator§ to an account provider for processing, settling, clearing§ and switching transactions (in relation to a payment system§) for: Austraclear§	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A89	Supply to other Australian ADIs§ for access to credit and debit electronic payments system	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A90	Fees and charges to an account provider in relation to an approved RTGS§ system	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A92	Fees and charges paid by participants§ in a payment system§ to operators to participate in a payment system: joint initiative or co-branding establishment fees§	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A93	Fees and charges paid by participants§ in a payment system§ to operators to participate in a payment system: to affiliate (co-branded credit cards§) for processing credit card§ transactions	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A94	Fees and charges paid by participants§ in a payment system§ to operators to participate in a payment system: direct entry fees§ for bulk corporate payment services, including payments from lists	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A95	Fees and charges paid by participants§ in a payment system§ to operators to participate in a payment system: outsourced remittance and mail preparation services	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A96	Fees and charges paid by participants§ in a payment system§ to operators to participate in a payment system: outsourced cheque§ production	Section 9-5 40-5.12 Items 2 and 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A97	Fees paid by participants in the BPAY§ scheme	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A98	Fees payable by participants to the operator under the BPAY§ Scheme	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A99	Fees payable by a participant to other participants under the BPAY§ Scheme	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§.
A100	Supply of a service by one participant§ in a payment system§ to another participant§ in the system in relation to charge, credit and debit card§ transactions	Section 9-5 40-5.12 Item 4	Taxable†	Account holders are not (in that capacity) participants§ in a payment system§. Example in Schedule 3, clause 2, Item 3.

Table A.11: FEES AND CHARGES PAYABLE BY A MERCHANT FOR MERCHANT OPERATIONS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A102	Sales processed fee	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A103	Merchant§ annual fees	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A104	Merchant§ transaction fees	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A105	Merchant§ monthly processing fees	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A106	Merchant§ establishment fees§	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A107	Imprinter and card terminal rental	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A108	Terminal installation and maintenance fee	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A109	Telecommunications line rental	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A110	Marketing fees	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A111	Risk management§ fees	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A112	Multi-currency fees	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A113	Payment system§ access and interchange§ facilities	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A114	Clearing§ and collection of funds on behalf of third parties	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A115	Operation of debit, credit and charge card§ payment facilities on behalf of third parties	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable
A116	Processing of account data	Section 9-5 40-5.12 Item 4	Taxable†	Not applicable

Table A.12: STORED VALUE^§ AND SIMILAR CARDS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A117	Stored value§ facility cards not linked to an account with an ADI	Section 9-5 40-5.12 Item 5	Taxable†	For credit, debit and charge cards§ with ADIs, see Line Nos. A21 to 23. For cards with non-ADIs, see Line Nos. B31 to B49. For prepaid travel cards or similar cards that are denominated in a foreign currency, refer to Line No. F16.
A118	Stored value facility cards linked to an account with an ADI	40-5.09(3) Item 1	Input taxed	See the Glossary for a definition of a stored value card§. For prepaid travel cards or similar cards that are denominated in a foreign currency refer to Line No. F16.
A119	Rent card§ (not a direct debit card§ and not linked to an ADI)	Section 9-5 40-5.12 Item 5	Taxable†	Akin to a stored value facility card or prepayment not linked to an account with an ADI. If the card is linked to an ADI and more akin to a debit card, the facility will be input taxed.

Table A.13: DEPOSIT^§ AND INVESTMENT

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
A121	Fees and charges between Australian ADIs§ and account holders: interest payments (including contingent payments)	40-5.09(3) Item 1	Input taxed	Payment of interest forms part of the consideration for a financial supply§.
A122	Fees and charges between Australian ADIs§ and account holders: early redemption penalties	40-5.09(3) Item 1	Input taxed	Not applicable

(b) After List point 2 in the Note before Table A.1, insert footnote 113C:

^113C Subsection 40-5.09(4) may apply to these fees where relevant and provided the conditions set out in the subsection are satisfied.

27. Table B. Summary of fees and services – Advances ^§ , Loans ^§ and Mortgages ^§

Omit the table, including the heading; substitute:

Summary of fees and services – Advances ^§ , Loans ^§ and Mortgages ^§

Table B.1: LOAN TRANSACTIONS: PROVISION OF CREDIT

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
B2	Application fees	40-5.09(3) Items 1 and 2 40-5.09(4)	Input taxed	Not applicable
B3	Approval fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B4	Establishment and agreement fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B5	Late payment or penalty fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B6	Rate lock fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B7	Administration fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B8	Participation fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B9	Discharge fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B10	Service fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B11	Commitment fees§	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B12	Drawing and redrawing§ fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B13	Enquiry fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B14	Limit fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B15	Line of credit§ fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B16	Statement and voucher§ fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B17	Settlement§ fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B18	Document inspection fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B19	Early repayment fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B20	Restructure fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B21	Interest payments	40-5.09(3) Items 1 and 2	Input taxed	Payment of interest forms part of the consideration for a financial supply§.
B22	Early repayment penalties	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B23	Other loan§ or advance§ related fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B24	Dishonour fee	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B25	Fee for moving to or from variable or fixed interest rate	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B26	Disbursements on-charged to customers as account-related fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B27	Advancement of principal§	Not consideration for provision, acquisition or disposal of an interest under 40-5.09(3)	Not subject to GST	Advancement and repayment of principal§ occurs under an agreement for a loan§ (a financial supply§) but is not itself a financial supply§; that is, it is not itself the provision, acquisition or disposal of an interest in or under item in subsection 40-5.09(3).
B28	Repayment of principal§	Not consideration for provision, acquisition or disposal of an interest under 40-5.09(3)	Not subject to GST	Not applicable
B29	Fees and charges by pawnbrokers§ to establish, maintain and discharge loan§	40-5.09(3) Item 2	Input taxed	Depending on facts, fee payable on collection of the goods may be for loan§ administration or storage. If paid for storage – the fee is consideration for a taxable supply. As it is for separate consideration it is not an incidental financial supply.
B30	Fees, charges and payments related to loans§ made to Australian residents in foreign currency	40-5.09(3) Items 1 and 2	Input taxed	Not applicable

Table B.2: CREDIT^§ AND CHARGE CARDS^§: PROVISION OF CREDIT AND CHARGE CARDS
Note: The extent to which the supply of a credit card facility is GST-free under table item 4 of subsection 38-190(1) is explained in GSTD 2017/1.

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
B32	Application fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B33	Establishment and closing fee	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B34	Additional card (same holder) fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B35	Additional (or second) cardholder fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B36	Replacement card fees and any associated courier costs	40-5.09(3) Items 1 and 2	Input taxed	Courier costs may be taxable if charged for separately.
B37	Interest payments	40-5.09(3) Items 1 and 2	Input taxed	Payment of interest forms part of the consideration for a financial supply§.
B38	Increase and exceed limit fees	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B39	Fee for not making a payment by due date	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B40	Fee for duplicate card statement or voucher§	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B41	Annual credit card§ fee	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B42	Foreign currency to Australian currency conversion fee	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B43	Over the counter and cash advance§ fee	40-5.09(3) Items 1 and 2	Input taxed	Not applicable
B44	Fee for effecting an ATM§ transaction	40-5.09(3) Items 1 and 2 and 40-5.09(5)	Input taxed	Not applicable
B45	Revolving credit§ facility fee	40-5.09(3) Item 2	Input taxed	Not applicable
B46	Loyalty program§ membership (supplied with card – no separate fee)	40-5.09(3) Items 1 and 2 40-5.10	Input taxed	GSTR 2012/1 provides guidance on the GST implications of certain loyalty programs.
B47	Loyalty program§ membership (supplied for separate fee)	Section 9-5 40-5.10	Taxable	Not incidental to the supply of an account under section 40-5.09. May be composite depending on the particular facts. GSTR 2012/1 provides guidance on the GST implications of certain loyalty programs.
B48	Card insurance (supplied with card – no separate fee)	40-5.09(3) Items 1 & 2 40-5.10	Input taxed	Not applicable
B49	Card insurance (supplied for separate fee)	Section 9-5 40-5.10	Taxable	Not incidental to the supply of an account under section 40-5.09. May be composite depending on the particular facts.

Table B.3: MORTGAGES^§ AND CHARGES^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
B50	Mortgage§ over land, premises or chattel§	40-5.09(3) Item 3	Input taxed	Not applicable
B52	Mortgage over a chattel: assignment§ or reassessment of asset fees	40-5.09(3) Item 3	Input taxed	Not applicable
B53	Mortgage over a chattel: registration of interest in the asset	40-5.09(3) Item 3	Input taxed	Not applicable
B54	Mortgage§ over a share§ or bond§	40-5.09(3) Item 3	Input taxed	Not applicable
B55	Switching of mortgages	40-5.09(3) Item 3	Input taxed	Not applicable
B56	Charge§ over the assets of a company	40-5.09(3) Item 3	Input taxed	Not applicable
B57	Fees and charges for documentation of the mortgage§ facility supplied by the mortgagee§ to the mortgagor§	40-5.09(3) Item 3	Input taxed	Not applicable
B58	Legal fees for preparing mortgage – other than when included as an on-charge by the mortgagee§	Section 9-5	Taxable‡	Not applicable
B60	Activities in relation to a charge§ or mortgage§ over real or personal property: valuation of the collateral§ or security for a credit or an advance§	40-5.09(3) Item 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B61	Activities in relation to a charge§ or mortgage§ over real or personal property: allowing mortgagor§ to inspect mortgage§ and security documents held by mortgagee§	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B62	Activities in relation to a charge§ or mortgage§ over real or personal property: making loan§ available on an ongoing basis	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B63	Activities in relation to a charge§ or mortgage§ over real or personal property: allowing more than one drawing down against mortgage§ loan§ account§	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B64	Activities in relation to a charge§ or mortgage§ over real or personal property: duplicate statements or statements outside the normal cycle for loan§	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B65	Activities in relation to a charge§ or mortgage§ over real or personal property: on-charge§ of costs to insure risk under loan§ or facilities secured by mortgage§	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B66	Activities in relation to a charge§ or mortgage§ over real or personal property: registration of mortgage§ with Land Titles Office	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B67	Activities in relation to a charge§ or mortgage§ over real or personal property: changes to certificate of title; for example, to update encroachments, to note subsequent borrowing, etcetera	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B68	Activities in relation to a charge§ or mortgage§ over real or personal property: moving to or from variable or fixed interest rate	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B69	Activities in relation to a charge§ or mortgage§ over real or personal property: change to the mortgage§ to reflect changes to mortgaged property	40-5.09(3) Items 2 and 3	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B70	Activities in relation to a charge§ or mortgage§ over real or personal property: draw down facility	40-5.09(3) Item 2	Input taxed	Assumes the services are provided as part of the supply of the charge§ or mortgage§ by the financial supply provider§ and not by a third party.
B71	Activities in relation to a charge§ or mortgage§ over real or personal property: discharge of mortgage§	40-5.09(3) Item 3	Input taxed	Only where a fee is not provided for under the mortgage. Otherwise a consequence of the mortgage§ rather than a separate supply; that is, not itself the provision, acquisition or disposal of an interest in an item under the regulations.
B72	Recovery§ of Commonwealth, State and Territory fees, duties and taxes	40-5.09(3) Item 3 See note	No supply if recovered Input taxed if on-charged	See paragraphs 191 to 197 of the Ruling for a discussion about recovery§ and on-charge§.
B73	Recovery§ of loan§ protection and title insurance	40-5.09(3) Item 3 see note	No supply if recovered§ Input taxed if on-charged§	See paragraphs 191 to 197 of the Ruling for a discussion about recovery§ and on-charge§.
B74	Recovery§ of professional and third party costs in connection with a mortgage§	40-5.09(3) Item 3 see note	No supply if recovered§ Input taxed if on-charged§	See paragraphs 191 to 197 of the Ruling for a discussion about recovery§ and on-charge§.
B75	Fee charged for production and inspection of title and mortgage§ documents for purposes other than under compulsion of law (for example, subpoena§)	40-5.09(3) Item 3	Input taxed	Not applicable
B76	Fee charged for production and inspection of title and documents produced under compulsion of law (for example, by subpoena§)	Section 9-5	Taxable‡	Not provided in connection with the mortgage§ and therefore not covered by subsection 40-5.09(3) item 3 or section 40-5.10.
B77	Sale of debtor's property by mortgagee§ in possession (where sale by debtor would not have been a taxable supply under subsection 105-5(1))	Subsection 105-5(1) Section 9-5 Div 38 Div 40	Not a taxable supply Varies according to fact situation	The GST status of the sale varies depending on the facts; for example, the sale may be input taxed, GST-free or 'out of scope' depending on the particular facts.
B78	Sale of debtor's property by mortgagee§ in possession (where sale by debtor would not have been a taxable supply because of subsection 105-5(3))	Subsection 105-5(3) Section 9-5 Div 38 Div 40	Not a taxable supply	The GST status of the sale varies depending on the facts; for example, the sale may be input taxed, GST-free or 'out of scope' depending on the particular facts.
B79	Sale of debtor's property by mortgagee§ in possession (where sale by debtor would have been a taxable supply)	Section 105-5(1) 40-5.12 Item 8 Div 105	Taxable†	Not applicable

Table B.4: DEBT^§ AND CREDIT ARRANGEMENTS^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
B80	Right to an income stream that is an interest in or under a debt§	40-5.09(3) Item 2	Input taxed	Not applicable
B81	Establishing, operating and terminating letters of credit	40-5.09(3) Item 2	Input taxed	Not applicable

28. Table C. Summary of fees and services – Trade Finance, Asset-Based Finance and Inventory-Based Finance

(a) Omit the table, including the heading and footnote 115; substitute:

Summary of fees and services – Trade Finance, Asset-Based Finance and Inventory-Based Finance

Table C.1: TRADE FINANCE: PROVISION OF IMPORT DOCUMENTARY LETTERS OF CREDIT (SERVICE PROVIDED BY AUSTRALIAN BANK TO AUSTRALIAN IMPORTER – GUARANTEES DEBT^§)

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
C2	Establishment and termination fees	40-5.09(3) Item 2	Input taxed	Not applicable
C3	Issuance fees	40-5.09(3) Item 2	Input taxed	Not applicable
C4	Document handling fees	40-5.09(3) Item 2	Input taxed	Not applicable
C5	Acceptance fees§	40-5.09(3) Item 2	Input taxed	Not applicable
C6	Amendment fees	40-5.09(3) Item 2	Input taxed	Not applicable
C7	Reimbursement fees	40-5.09(3) Item 2	Input taxed	Not applicable
C8	Extension and increase fees	40-5.09(3) Item 2	Input taxed	Not applicable

Table C.2: TRADE FINANCE: PROVISION OF EXPORT DOCUMENTARY LETTERS OF CREDIT (SERVICE PROVIDED TO OVERSEAS BANK BY AUSTRALIAN BANK)

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
C10	Document handling fees	Section 38-190	GST-free	The GST status of the supply for which the fee, etcetera is paid may vary depending on the facts of the supply – that is: •  where the supply satisfies section 38-190, it is GST-free •  if the supply is by financial supply facilitator it is taxable. If it is the provision, acquisition or disposal of a financial interest by a financial supply provider it is input taxed.
C11	Advising fees	Section 38-190	GST-free	The GST status of the supply for which the fee, etcetera is paid may vary depending on the facts of the supply – that is: •  where the supply satisfies section 38-190, it is GST-free •  if the supply is by financial supply facilitator it is taxable. If it is the provision, acquisition or disposal of a financial interest by a financial supply provider it is input taxed.
C12	Negotiation fees§	Section 38-190	GST-free	The GST status of the supply for which the fee, etcetera is paid may vary depending on the facts of the supply – that is: •  where the supply satisfies section 38-190, it is GST-free •  if the supply is by financial supply facilitator it is taxable. If it is the provision, acquisition or disposal of a financial interest by a financial supply provider it is input taxed.
C13	Discrepancy fees	Section 38-190	GST-free	The GST status of the supply for which the fee, etcetera is paid may vary depending on the facts of the supply – that is: •  where the supply satisfies section 38-190, it is GST-free •  if the supply is by financial supply facilitator it is taxable. If it is the provision, acquisition or disposal of a financial interest by a financial supply provider it is input taxed.
C14	Without Recourse§ fees	Section 38-190	GST-free	The GST status of the supply for which the fee, etcetera is paid may vary depending on the facts of the supply – that is: •  where the supply satisfies section 38-190, it is GST-free •  if the supply is by financial supply facilitator it is taxable. If it is the provision, acquisition or disposal of a financial interest by a financial supply provider it is input taxed.
C15	Assignment fees	Section 38-190	GST-free	The GST status of the supply for which the fee, etcetera is paid may vary depending on the facts of the supply – that is: •  where the supply satisfies section 38-190, it is GST-free •  if the supply is by financial supply facilitator it is taxable. If it is the provision, acquisition or disposal of a financial interest by a financial supply provider it is input taxed.

Table C.3: TRADE FINANCE: OTHER

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
C16	Fees and charges relating to collections and remittance services related to export transactions (service provided by Australian bank to Australian exporter), for example, amendment and dishonour fees	Section 38-190 Section 40-5.09 Section 9-5 See note	Input taxed or Taxable depending on whether as provider or facilitator	The supply is input taxed where the bank takes a principal interest in debt§. The supply is taxable if the bank acts as facilitator. The supply is not GST-free as it is not within section 38-190.
C17	Fees and charges relating to collections and remittance services related to import transactions (bank providing service to overseas bank)	Section 38-190	GST-free	Not applicable
C18	Fees and charges relating to trade guarantees (including bills of lading guarantees) or bonds§	40-5.09(3) Item 7	Input taxed	Not applicable
C19	Fees, charges and payments relating to forfaiting§	40-5.09(3) Item 2	Input taxed	Not applicable

Table C.4: ASSET-BASED FINANCE^114A

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
C20	Payments relating to the sale of goods	Section 9-5	Taxable‡	Not applicable
C22	Fees and charges for the supply of finance under a hire purchase§ agreement entered into before 1 July 2012 for the supply of goods where the credit charge is not disclosed to the recipient of the goods: hire charges, rent or instalments	Section 9-5	Taxable‡	Not covered by item 8 of subsection 40-5.09(3) because interest component is not separately disclosed.
C24	Fees and charges for the supply of finance under a hire purchase§ agreement entered into before 1 July 2012 for the supply of goods where the credit charge is disclosed to the recipient of the goods: hire charges, rent or instalments	Section 9-5 40-5.09(3) Item 8	Taxable or Input taxed	Only credit component is financial supply§. Principal component is taxable.
C25	Fees and charges for the supply of finance under a hire purchase§ agreement entered into before 1 July 2012 for the supply of goods where the credit charge is disclosed to the recipient of the goods: credit charges, including interest and associated fees	40-5.09(3) Item 8	Input taxed	Fees associated with the provision of an interest in credit under the hire purchase§ arrangement are input taxed; for example, an establishment fee§
C25A	The fees and charges for the supply of goods and finance under a hire purchase§ agreement entered into on or after 1 July 2012	Section 9-5 40-5.12 Items 19 and 20	Taxable	Schedule 3, clause 7, item 1
C26	Assignment§ or reassessment of asset fees under a hire purchase agreement entered into before 1 July 2012	40-5.09(3) Item 8	Input taxed	To the extent that the fee relates to the credit component it is input taxed.
C26A	Assignment§ or reassessment of asset fees under a hire purchase agreement entered into on or after 1 July 2012	Section 9-5 40-5.12 Items 19 and 20	Taxable	Schedule 3, clause 7, item 1
C27	Fees and charges for deferred purchase by the purchaser including hire charges, rent or instalments	Section 9-5	Taxable‡	Not applicable
C28	Fees and charges for leases§ by the lessee including lease§ charges, rent or instalments	Section 9-5 40-5.12 Item 6	Taxable†	Not applicable

Table C.5: STAMP DUTIES AND OTHER STATE AND COMMONWEALTH DUTIES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
C29	On-charging of stamp duties and other Government taxes and charges associated with the supply of goods under an HP agreement	Section 9-5	Taxable‡ (that is, relates to transfer of title to the goods)	An 'on-charged' stamp duty, tax or charge loses its character (as a tax fee or charge that is not taxable under Div 81) and becomes an input to the underlying supply of the good. See paragraphs 195 to 196 of the Ruling.

Table C.6: INVENTORY OR RECEIVABLES FINANCE

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
C30	Receivables factoring§ and accounts receivable financing§ fees and charges levied by the seller	40-5.09(3) Item 2	Input taxed	Fees or charges levied by the seller for services provided by the seller are taxable.
C31	Fees and charges levied by the financier for the assignment§ or sale of receivables (that is, fee for assignment of debt§) or loans§ secured over receivables	40-5.09(3) Item 2	Input taxed	Fees or charges levied by the financier for services provided by the financier are taxable.
C32	Floor plan and inventory financing transactions fees and charges	Section 9-5 40-5.12 Item 18	Taxable†	Not applicable
C33	Sales accounting services under a factoring§ arrangement	Section 9-5 40-5.12 Item 14	Taxable†	Not applicable
C34	Fees and charges for factoring§ of taxi vouchers§ by taxi drivers	40-5.09(3) Item 2	Input taxed	Not applicable
C35	Fees and charges relating to bailment§	Section 9-5 40-5.12 Item 18	Taxable†	Not applicable
C36	Fees and charges for floor plan arrangements§	Section 9-5 40-5.12 Item 18	Taxable†	Not applicable
C37	Establishment fees§ and charges for receivables factoring§ and invoice financing arrangements	40-5.09(3) Item 2	Input taxed	Not applicable
C38	Settlement§ fees for receivables factoring§ and invoice financing accounts	40-5.09(3) Item 2	Input taxed	Not applicable
C39	Fees and charges for export receivables factoring§ and invoice financing arrangements	40-5.09(3) Item 2	Input taxed	Not applicable
C40	Fees and charges for import receivables factoring§ and invoice financing arrangements	Section 38-190	GST-free	Not applicable

(b) After ASSET-BASED FINANCE in the Heading for Table C.4, insert new footnote 114A:

^114A See Line No. C29 re treatment of stamp duties.

29. Table D. Summary of fees and services – Securities ^§

Omit the table, including the heading; substitute:

Summary of fees and services – Securities ^§

Table D.1: SECURITIES^§: SUPPLIED BY A FINANCIAL SUPPLY PROVIDER^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
D2	Bonds§ and bearer instruments (securities)§, including funeral bonds that are securities	40-5.09(3) Item 10(a)	Input taxed	Not applicable
D3	Bonds§, stocks or debentures§ issued by a government entity	40-5.09(3) Item 10(a)	Input taxed	Not applicable
D4	Shares§ in a body	40-5.09(3) Item 10	Input taxed	Not applicable
D4A	Shares in a corporate collective investment vehicle (CCIV)	40-5.09(3) Item 10	Input taxed	A share in a CCIV is a security under the Corporations Act. However, for tax purposes, a share referable to a CCIV sub-fund is taken to be a unit in a unit trust (the CCIV sub-fund trust). See Subdivision 195-C of the ITAA 1997.
D5	Debentures§ or convertible notes§ issued by a body	40-5.09(3) Item 10(a)	Input taxed	Not applicable
D6	A document issued by an individual that would be a debenture§ if issued by a body corporate	40-5.09(3) Item 10(b)	Input taxed	Not applicable
D7	Promissory notes§ and bills of exchange	40-5.09(3) Item 10(a)	Input taxed	Subparagraph (c)(iii) and paragraph (d) of the definition of debenture§ in section 9 of the Corporations Act. Given as an example of item 10 in Schedule 2, clause 9, item 8.
D8	Dealings in floating rate notes§, commercial bills§, commercial paper§, extendable bill investments and other financial instruments (for example, assignment§, acceptance or discounting)	40-5.09(3) Item 10	Input taxed	Given as an example of item 10 in Schedule 2, clause 9, item 6.
D9	Bank cheques§	40-5.09(3) Item 10	Input taxed	Subparagraph (c)(i) of the definition of debenture§ in section 9 of the Corporations Act. Schedule 2, clause 9, item 9.
D10	Structured notes§	40-5.09(3) Item 10	Input taxed	Given as an example of item 10 in Schedule 2, clause 9, item 4.
D11	Subordinated notes§	40-5.09(3) Item 10	Input taxed	Given as an example of item 10 in Schedule 2, clause 9, item 3.
D12	Fixed income securities§	40-5.09(3) Item 10	Input taxed	Not applicable
D13	Payment of dividends§	No provision, acquisition or disposal of an interest	Not subject to GST	Payment of a dividend§ is not regarded as consideration for a supply by shareholders for GST purposes however this does not mean that it may not be consideration for another supply; for example, if forgone in exchange for shares.§

Table D.2: SECURITIES^§: OTHER

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
D14	Interests in or under the capital of a partnership	40-5.09(3) Item 10(d)	Input taxed	See GSTR 2003/13 for general law partnerships. A supply of a financial interest under table item 10(d) of subsection 40-5.09(3) does not arise in situations involving tax law partnerships – see GSTR 2004/6.
D15	Cash distributions from a partnership	No provision, acquisition or disposal of an interest	Not subject to GST	Not applicable
D16	Interests in or under the capital of a trust§	40-5.09(3) Item 10(d)	Input taxed	Not applicable
D17	Cash distributions from a trust	No provision, acquisition or disposal of an interest	Not subject to GST	Not applicable
D18	Time share§ schemes	40-5.09(3) Item 10(c)	Input taxed	Paragraph (b) of the definition of managed investment scheme§ in section 9 of the Corporations Act.
D18A	Company title§ schemes	40-5.09(3) Item 10	Input taxed	Not applicable
D19	Securities lending§ by a financial supply provider§	40-5.09(3) Item 10	Input taxed	Not applicable
D20	Securities lending§ agency fees	Section 9-5	Taxable†	Not applicable
D21	Money orders§ and postal notes	40-5.09(3) Item 10	Input taxed	Not applicable

Table D.3: SECURITIES^§: MANAGED INVESTMENT SCHEMES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
D23	Retail and wholesale managed funds	40-5.09(3) Item 10	Input taxed	Where a scheme is not registered as a managed investment scheme§, or is not entitled to regulatory relief from being registered, the supply of an interest in such a scheme will still be covered by this item.
D24	An interest in an Investor Directed Portfolio Service (IDPS) such as: - wrap accounts§ - member discretionary masterfunds or IDPS-like arrangements	40-5.09(3) Item 10	See notes	In each case it is necessary to consider whether or not an enterprise is being carried on in respect of the product. Where the IDPS amounts to an entity that is carrying on an enterprise, an interest in the IDPS will be an input taxed supply.
D25	Mortgage investment schemes§	40-5.09(3) Item 10	Input taxed	Where a scheme is not registered as a managed investment scheme§, or is not entitled to regulatory relief from being registered, the supply of an interest in such a scheme will still be covered by this item.
D26	An interest in a scheme in which all of the members are bodies corporate that are related to each other and to the body corporate that promotes the scheme	40-5.09(3) Item 10(c)	Input taxed	Paragraph (e) of the definition of managed investment scheme§ in section 9 of the Corporations Act.
D27	An interest in a scheme operated by an Australian ADI§ in the ordinary course of its banking business§	40-5.09(3) Item 10(c)	Input taxed	Paragraph (i) of the definition of managed investment scheme§ in section 9 of the Corporations Act.
D28	An interest in a barter§ scheme under which each participant may obtain goods or services from another participant for consideration that is wholly or substantially in kind rather than in cash	40-5.09(3) Item 10(c)	Input taxed	Paragraph (k) of the definition of managed investment scheme§ in section 9 of the Corporations Act. Supplies of goods or services between participants are not interests in the scheme.
D29	An interest in a scheme that is operated by a co-operative company registered under Part VI of the Companies (Co-operative) Act 1943 of Western Australia or under a previous law of Western Australia that corresponds to that part	40-5.09(3) Item 10(c)	Input taxed	Paragraph (m) of the definition of managed investment scheme§ in section 9 of the Corporations Act.
D30	Fees and charges for borrowing and lending securities§ through a repurchase (repo) or reverse repurchase§ (reverse repo§), including stock lending	40-5.09(3) Item 10	Input taxed	Where a scheme is not registered as a managed investment scheme§, or is not entitled to regulatory relief from being registered, the supply of an interest in such a scheme will still be covered by this item.

Table D.4: SECURITIES^§: SECURITISATION ARRANGEMENT

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
D32	Assignment§ of an income stream	40-5.09(3) Item 2	Input taxed	Not applicable
D33	Issue of bond§ or debenture§	40-5.09(3) Item 10	Input taxed	Not applicable
D34	Rating service§	40-5.09(3) Item 10	Input taxed	If the rating service is provided separately and constitutes an aim in itself, the supply will be taxable under item 3, section 40-5.12.
D35	Co-ordinating the issue of debt securities by the special purpose vehicle§	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
D36	Arrangement by a financial supply facilitator§ of the provision, acquisition or disposal of an interest in a security (for example, broking services)	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
D37	An investor's contribution to a managed investment scheme (including entry fees§ debited from the investor's contribution to the scheme) for the investor's acquisition of an interest in a managed investment scheme§	40-5.09(3) Item 10	Input taxed	When a member makes a contribution to a managed investment scheme, the total contribution made is consideration for the interest in the scheme. When part of that contribution is then debited by the scheme from the member's account or investment as an entry fee, there is no further supply made to the investor by the scheme. When entry fees are payable in other circumstances, such as the investor making a payment to an entity other than the managed investment scheme entity, the GST treatment of these arrangements needs to be considered on a case-by-case basis. For example, as established in Hance v Commissioner of Taxation [2008] FCAFC 196, some agricultural managed investment schemes may be structured so that investors carry on individual enterprises, and some fees payable may be consideration for taxable supplies.
D37A	Exit fees§ debited by the scheme from a member's investment in the scheme when the investor makes a disposal of their interest in a managed investment scheme§	Not consideration for the provision, acquisition or disposal of an interest	Not subject to GST	When exit fees are included in the calculation of the consideration paid by the managed investment scheme for the member's disposal of the interest in the scheme, they are not separately treated as consideration for the member's disposal of an interest in a managed investment scheme or for any other supply to the member. However, when exit fees are payable in other circumstances, such as the investor making a payment to an entity other than the managed investment scheme entity, the GST treatment of these arrangements needs to be considered on a case-by-case basis.
D38	Ongoing management (or similar) fees that are debited by the scheme against the investor's account in the managed investment scheme§	Not consideration for the provision, acquisition or disposal of an interest	Not subject to GST	This is an element of calculating the return to an investor rather than consideration for any supply made by a managed investment scheme§ to an individual member.
D39	Clearance and settlement§ of securities§ or derivatives§	40-5.12 Item 9	Taxable†	Not applicable
D40	Facilities for trading securities§ or derivatives§	40-5.12 Item 9	Taxable†	Not applicable
D41	Underwriting§ of securities§ (for example, shares§ or debentures§) as financial supply provider§	40-5.09(3) Items 10 and 11	Input taxed	Underwriting§ involves a number of different activities. Where the underwriter agrees to place or take up securities it is unable to place, the fee will be both for supplies it makes as a financial supply provider and a financial supply facilitator. Only that part relating to the supplies as a financial supply provider will be input taxed. The fee will need to be apportioned into its taxable and input taxed components. (Paragraphs 91 to 98 of this Ruling discuss mixed and composite supplies.)
D42	Best endeavours underwriting§	Section 9-5	Taxable†	Not the provision of an interest mentioned in the table in subsection 40-5.09(3).

30. Table E. Summary of fees and services – Guarantees ^§ and indemnities ^§

Omit the table, including the heading; substitute:

Summary of fees and services – Guarantees ^§ and indemnities ^§

Table E.1: GUARANTEES^§ AND INDEMNITIES^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
E1	An indemnity§ that is not a contract of insurance	40-5.09(3) Item 7A	Input taxed	Prior to 1 July 2012, an indemnity was covered by subsection 40-5.09(3) Item 7
E2	A surety bond that is a guarantee§	40-5.09(3) Item 7	Input taxed	Not applicable
E3	A performance bond that is not a contract of insurance	40-5.09(3) Item 7 40-5.09(3) Item 7A	Input taxed	A guarantee is covered by Item 7. An indemnity is covered by Item 7A. Prior to 1 July 2012, an indemnity was covered by Item 7.
E4	Bank guarantees§ and bonds§	40-5.09(3) Item 7 40-5.09(3) Item 7A	Input taxed	A guarantee is covered by Item 7. An indemnity is covered by Item 7A. Prior to 1 July 2012, an indemnity was covered by Item 7.
E5	Establishing, operating and terminating letters of credit	40-5.09(3) Item 2	Input taxed	Not applicable
E6	Warranty for goods	40-5.12 Item 21 Section 9-5	Taxable	Prior to 1 July 2012, a warranty for goods was excluded from being a financial supply§ by Item 7 of subsection 40-5.09(3).

31. Table F. Summary of fees and services – Currency

Omit the table, including the heading; substitute:

Summary of fees and services – Currency

Table F.1: CURRENCY: RELATING TO AUSTRALIAN CURRENCY, THE CURRENCY OF A FOREIGN COUNTRY, DIGITAL CURRENCY, OR AN AGREEMENT TO BUY OR SELL ANY OF THESE 3 THINGS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
F2	Conversion of foreign to domestic currency	40-5.09(3) Item 9	Input taxed	Not applicable
F3	Foreign currency drafts§	40-5.09(3) Item 9	Input taxed	A separate supply of a foreign currency draft is GST-free under table item 4 of subsection 38-190(1) when the draft must be presented to a bank outside Australia. Where the foreign currency draft is a transaction under the supply of a transaction account, GSTD 2020/1 will be relevant.
F4	Foreign currency notes§ where the recipient intends to use the notes outside of Australia	Subsection 38-190(1) Item 4	GST-free	If the recipient of the notes intends to use the notes in Australia (for example, to on supply the notes to another entity in Australia), the supply of the notes to the recipient will not be GST free, but will be input taxed under item 9 of subsection 40-5.09(3).
F5	Fees for travellers cheques§ issued by principal§	40-5.09(3) Item 9	Input taxed	GST-free under table item 4 of subsection 38-190(1) when payee intends to use travellers cheques while located outside Australia.
F6	Fees for repurchase of travellers cheques§ by principal§	40-5.09(3) Item 9	Input taxed	Not applicable
F7	International cheques§	40-5.09(3) Item 9	Input taxed	A separate supply of an international cheque is GST-free under table item 4 of subsection 38-190(1) when the cheque must be presented at a bank outside Australia. Where the international cheque is a transaction under the supply of a transaction account, GSTD 2020/1 will be relevant.
F8	Forward contracts§ for transactions to buy or sell foreign currency	40-5.09(3) Items 9 and 11	Input taxed	GST-free under table item 4 of subsection 38-190(1) when currency is delivered to an overseas account.
F9	Options§ to buy or sell foreign currency	40-5.09(3) Items 9 and 11	Input taxed	The supply of a call option will be GST-free if the delivery of currency on exercise of option would itself be a GST-free supply (that is, a forex spot delivered to an overseas account) (paragraph 9-30(1)(b)).
F10	Collection, negotiation§ and endorsement§ of instruments (including cheques§) for payment in foreign currency, including message services	40-5.09(3) Item 9	Input taxed	Not applicable
F11	Purchase and sale of cash	40-5.09(3) Item 9	Input taxed	Not applicable
F11A	Purchase and sale of digital currency	40-5.09(3) Item 9	Input taxed	Not applicable
F12	Changing cash into different denominations	40-5.09(3) Item 9	Input taxed	Not applicable
F13	Fees levied by agent for travellers cheques§ distributed by agent acting on behalf of issuer	Section 9-5	Taxable‡	Where the supply of the travellers cheque (Line No. F5) is GST-free under table item 4 of subsection 38-190(1), the supply of the service by the agent will also be GST-free under table item 4.
F14	Fees levied by agent acting on behalf of issuer for the services of facilitating the repurchase of travellers cheques§	Section 9-5	Taxable‡	Not applicable
F15	Fees and charges for the purchase or sale of Australian currency or the currency of a foreign country for an amount exceeding the stated legal tender value (other than precious metals§)	Section 9-5 40-5.12 Item 17	Taxable†	This item refers to money of numismatic§ interest; that is, it is intended to be collected rather than currency bought and sold for use as currency.
F16	Supply of prepaid travel cards or similar cards issued by an Australian ADI loaded with Australian or foreign currency	Subsection 38-190(1) Item 4	GST-free	Only GST-free to the extent the card is intended to be used when the cardholder is outside Australia and the cardholder's physical presence outside Australia is integral to the transaction. To the extent the supply is not GST-free, it will be input taxed under Item 1 or Item 9 of subsection 40-5.09(3).

32. Table G. Summary of fees and services – Superannuation, Annuities & Allocated pensions ^§

Omit the table, including the heading; substitute:

Summary of fees and services – Superannuation, Annuities and Allocated pensions ^§

Table G.1: SUPERANNUATION

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
G1	Capital contributions to a regulated superannuation fund§, an approved deposit§ fund§, a pooled superannuation trust§ or a public sector superannuation scheme§ within the meaning of the Superannuation Industry (Supervision) Act 1993, or an RSA (retirement savings account) within the meaning of the Retirement Savings Accounts Act 1997	40-5.09(3) Item 4	Input taxed	Not applicable
G2	[Omitted.]	[Omitted.]	[Omitted.]	[Omitted.]
G3	Ongoing management (or similar) fees§ that are debited against the member's account in the superannuation fund§	Not consideration for the provision, acquisition or disposal of an interest	Not subject to GST	This is an element of calculating the return to a member rather than consideration for any supply made by a superannuation fund§ to an individual member.
G5	Fees, charges or payments relating to rollover bonds§ charged to a superannuation fund: management service fees	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
G6	Fees, charges or payments relating to rollover bonds§ charged to a superannuation fund: transfer (fund switch) fees	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
G7	Fees, charges or payments relating to rollover bonds§ charged to a superannuation fund: cheque§ issuing fees	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable

Table G.2: ANNUITIES OR ALLOCATED PENSIONS^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
G8	Capital contributions, rollovers§, fees or other payments to superannuation funds§ to establish a pension or allocated pensions§	40-5.09(3) Item 5	Input taxed	Not applicable
G9	Capital contributions, rollovers§, fees or other payments to superannuation funds§ to establish an annuity§ or allocated annuity§	40-5.09(3) Item 5	Input taxed	Not applicable

33. Table H. Summary of fees and services – Derivatives ^§

Omit the table, including the heading; substitute:

Summary of fees and services – Derivatives ^§

Table H.1: DERIVATIVES^§: FORWARD CONTRACTS^§, FUTURES CONTRACTS^§, SWAP CONTRACTS AND OPTIONS^§ CONTRACTS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
H2	The price of debt securities§ or debt securities index values or interest rates	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 1(a).
H3	Foreign exchange or currency values or currency index values	40-5.09(3) Items 9 and 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 1(b).
H4	Share§ or stock prices or equity index values	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 1(c).
H5	Credit spreads§ or credit events, including: -  default; -  other forms of financial distress; and -  credit index values	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 1(d).
H6	Macroeconomic indicators or variables	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 1(e).
H7	Climatic events or indexes	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 1(f).

Table H.2: DERIVATIVES^§: OTHER

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
H8	Commodity derivatives§ that involve no option, right or obligation to delivery of a commodity	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 2. Refer to Line Nos. N1 to N5 in relation to commodity transactions, deliverable wool futures and forward contracts (or options over such futures or contracts).
H9	Reciprocal repurchase agreements§	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 3.
H10	Options§ over input taxed supplies of precious metals§	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 4.
H11	Securities§ lending agreements	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 5.
H12	Initial and variation margins§ in respect of exchange traded futures contracts§	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 6.
H13	Cash settlement§ of a derivative§ over the counter or on the exchange rather than the physical delivery of the underlying taxable assets	40-5.09(3) Item 11	Input taxed	Given as an example of item 11 in Schedule 2, clause 10, item 7. Refer to Line Nos. N1 to N5 in relation to commodity transactions, deliverable wool futures and forward contracts (or options over such futures or contracts).
H14	Derivatives structuring fees	Section 9-5	Taxable†	Not applicable
H15	Warrants§	40-5.09(3) Item 11	Input taxed	Not applicable

34. Table I. Summary of fees and services – Insurance

Omit the table, including the heading; substitute:

Summary of fees and services – Insurance

Note: Life insurance business means business that consists of issuing of life policies; issuing of sinking fund policies; undertaking of liability under life policies; undertaking of liability under sinking fund policies; and any related business^§. It includes business declared to be life insurance business.

Table I.1: INSURANCE SERVICES: LIFE INSURANCE BUSINESS^§ (TO WHICH SUBSECTION 9(1) OF THE LIFE INSURANCE ACT 1995 APPLIES)

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
I2	A contract of insurance that provides for the payment of money§ on the death of a person or on the happening of a contingency dependent on the termination or continuance of human life	40-5.09(3) Item 6	Input taxed	Related business includes business relating to the investment, administration and management of the assets of a statutory fund. Given as an example of item 6 in Schedule 2, clause 4, item 1.
I3	A contract of insurance that is subject to payment of premiums§ for a term dependent on the termination or continuance of human life	40-5.09(3) Item 6	Input taxed	Given as an example of item 6 in Schedule 2, clause 4, item 2.
I4	A contract of insurance that provides for the payment of an annuity§ for a term dependent on the continuance of human life	40-5.09(3) Item 6	Input taxed	Given as an example of item 6 in Schedule 2, clause 4, item 3.
I5	A continuous disability policy§ (within the meaning of section 9A of the Life Insurance Act 1995)	40-5.09(3) Item 6	Input taxed	Given as an example of item 6 in Schedule 2, clause 4, item 5.
I6	A contract that provides for the payment of an annuity§ (in excess of the term prescribed in the Life Insurance Regulations) for a term, not dependent on the continuance of human life	40-5.09(3) Item 6	Input taxed	Given as an example of item 6 in Schedule 2, clause 4, item 4.
I7	An investment account contract§ or an investment-linked contract§ (within the meaning of section 14 of the Life Insurance Act 1995)	40-5.09(3) Item 6	Input taxed	Given as an example of item 6 in Schedule 2, clause 4, item 6.
I8	Related reinsurance§ business	40-5.09(3) Item 6	Input taxed	Not applicable
I9	Life insurance business§ declared to be life Insurance business under subsection 12(2) section 12A or 12B of the Life Insurance Act 1995, or related reinsurance§ business	40-5.09(3) Item 6	Input taxed	Not applicable

Table I.2: INSURANCE SERVICES: OTHER

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
I10	A funeral bond that is a contract of life insurance	40-5.09(3) Item 6	Input taxed	Not applicable
I11	A contract of consumer credit insurance within the meaning of the Insurance Contracts Act 1984	Division 78	Taxable	This is not a continuous disability policy§ and therefore is not a life policy§ within the meaning of the Life Insurance Act 1995.
I12	A contract of private health insurance	Subsection 38-55(1)	GST-free	A health insurance policy is not a continuous disability policy§ within the meaning of the Life Insurance Act 1995.
I13	A contract of insurance against liability to pay for services supplied by ambulance	Subsection 38-55(2)	GST-free	Not applicable
I14	A contract of insurance for indemnification against (continuous) disability	40-5.09(3) Item 6	Input taxed	Not applicable
I15	A contract of insurance that provides for the payment of income benefits during the absence of a person from work due to temporary disability (e.g., salary continuance insurance§)	Section 9-5 40-5.12 Item 10	Taxable†	Salary continuance insurance§ is not continuous disability insurance within the meaning of the Life Insurance Act 1995.
I16	A contract of insurance for indemnification against casualty or property damage (including public liability or third party damage)	Section 9-5 40-5.12 Item 10	Taxable†	Not applicable
I17	Brokerage§ of insurance (including initial or trailing commissions§)	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
I18	A contract of insurance for indemnification against credit risk or credit losses	Section 9-5 40-5.12 Item 10	Taxable†	Not applicable
I19	Compensation paid to a beneficiary of an insurance policy covering credit risk or credit losses	40-5.12 Item 10 and Division 78	Taxable†	Not applicable

35. Table J. Summary of fees and services – Advisory & Professional services

Omit the table, including the heading; substitute:

Summary of fees and services – Advisory and Professional services

Table J.1: ADVISORY AND PROFESSIONAL SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
J1	Advice by a legal practitioner in the course of professional practice	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J2	Advice by an accountant in the course of professional practice	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J3	Advice by a taxation practitioner including preparation of tax returns and business activity statements	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J4	Advice by an actuary§	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J5	Rating services for securitisation§ vehicles	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J6	Advisory services about syndicated loan§ facilities	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J7	Advice about corporate finance transactions	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J8	Advice about financial and investment alternatives	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J9	General financial advice other than about the operation of accounts or the granting of credit	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J10	Valuation services provided by a professional valuer to a financial supply provider§	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table J.2: FEES AND CHARGES FOR ADVICE, RESEARCH, INFORMATION, ANALYSIS OR OTHER SIMILAR SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
J12	Mergers and acquisitions	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J13	Corporate restructuring	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J14	Fund raising	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J15	Risk management§	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J16	Financial management, corporate management, business strategy and management	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J17	Industry or market structure products	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table J.3: FINANCIAL PLANNING

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
J18	Advice and administration services for estate planning	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J19	Assessment of financial position and facilitating financial transactions	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J20	Advising on investment strategies and portfolio planning	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J21	Facilitating financial structures and planning	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
J22	Portfolio analysis and review	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

36. Table K. Summary of fees and services – Brokerage ^§ & Facilitator Services

Omit the table, including the heading; substitute:

Summary of fees and services – Brokerage ^§ and Facilitator Services

Table K.1: BROKERAGE^§ AND FACILITATOR SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
K1	Brokerage§, Commission§ or both	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K2	Origination fees	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K4	Services by a broker or financial supply facilitator§: procuring counterparties to a financial supply§ transaction (for example, syndicated loans§)	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K5	Services by a broker or financial supply facilitator§: arranging deposit§, loan§ and securities§ transactions	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K6	Services by a broker or financial supply facilitator§: arranging asset based finance, trade finance and inventory or receivable finance transactions	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K7	Services by a broker or financial supply facilitator§: arranging financial transactions	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K8	Services by a broker or financial supply facilitator§: arranging commodity transactions	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K9	Fees and charges for arranging insurance or risk indemnification transactions	Section 9-5 40-5.12 Item 11	Taxable†	Not applicable
K11	Underwriting§ by a financial supply facilitator§: advisory services	Section 9-5 40-5.12 Item 3	Taxable†	Underwriting§ of a security (for example, a share§ or debenture§) may be input taxed if the underwriter agrees to take up securities§ it is unable to place.
K12	Underwriting§ by a financial supply facilitator§: CHESS§ sponsorship	Section 9-5 40-5.12 Item 11	Taxable†	Underwriting§ of a security (for example, a share§ or debenture§) may be input taxed if the underwriter agrees to take up securities§ it is unable to place.
K13	Underwriting§ by a financial supply facilitator§: nominee§ or custodian services	Section 9-5 40-5.12 Item 16	Taxable†	Underwriting§ of a security (for example, a share§ or debenture§) may be input taxed if the underwriter agrees to take up securities§ it is unable to place.
K14	Underwriting§ by a financial supply facilitator§: arrangement of scrip loan facilities	Section 9-5 40-5.12 Item 9 or 11	Taxable†	Underwriting§ of a security (for example, a share§ or debenture§) may be input taxed if the underwriter agrees to take up securities§ it is unable to place.

37. Table L. Summary of fees and services – Trustee ^§ and custodian services

Omit the table, including the heading; substitute:

Summary of fees and services – Trustee ^§ and custodian services

Table L.1: CUSTODY^§ SERVICES: CORE CUSTODY SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L2	Clean payments made on behalf of another entity	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L3	Settling and undertaking of securities§ transactions at the direction of the custodian§ client	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L4	Collecting income and other payments with respect to the securities§ in the fund	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L5	Proxy voting§	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L6	Portfolio reporting – settlement§ activity, recurrent reporting	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L7	Option§ trading services made on behalf of another entity	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L8	Cheque§ drawing	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L9	Asset reconciliation§	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L10	Daily cash reconciliation and reporting	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L11	Acting as escrow agent§	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L12	Clearing§ and settling securities§ or derivatives§ trades	Section 9-5 40-5.12 Item 9	Taxable†	Not applicable
L13	Transaction authorisation (acting as nominee§ under Power of Attorney§)	Section 9-5 40-5.12 Items 3 and 16	Taxable†	Not applicable
L14	Opening and maintaining bank accounts to facilitate settlement§ of security transactions	Section 9-5 40-5.12 Item 16	Taxable†	This is a fee for a service and distinct from the fee charged by an ADI to open an account which is a financial supply§ under item 1 of subsection 40-5.09(3).

Table L.2: CUSTODY^§ SERVICES: MASTER CUSTODY SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L16	Maintenance of accounting records	Section 9-5 40-5.12 Item 16	Taxable†	Item 12 of section 40-5.12 may also apply
L17	Pricing of securities§	Section 9-5 40-5.12 Item 16	Taxable†	Item 12 of section 40-5.12 may also apply
L18	Taxation reporting	Section 9-5 40-5.12 Items 3 and 16	Taxable†	Item 12 of section 40-5.12 may also apply
L19	Mandate§ monitoring	Section 9-5 40-5.12 Item 16	Taxable†	Item 12 of section 40-5.12 may also apply
L20	Trade execution monitoring	Section 9-5 40-5.12 Item 16	Taxable†	Item 12 of section 40-5.12 may also apply

Table L.3: CUSTODY^§ SERVICES: ACCOUNTING AND ADMINISTRATION SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L22	Portfolio performance analysis	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L23	Risk management§ reporting	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L24	Management accounting	Section 9-5 40-5.12 Items 3 and 12	Taxable†	Not applicable
L25	Cash management	Section 9-5 40-5.12 Items 3 and 12	Taxable†	Not applicable
L26	Unit registry§ services	Section 9-5 40-5.12 Items 3, 12 and 16	Taxable†	Not applicable
L27	Statutory accounts preparation	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L28	Tax return (including BAS) preparation	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L29	Preparation of Superannuation returns	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L30	Maintenance or access to property portfolio database	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table L.4: REPORTING AND COMPLIANCE SERVICES: TAXATION REPORTS AND ACCOUNTS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L32	Foreign Investment Fund§ (FIF) compliance	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L33	Reconciliation of accounting income to taxable income	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L34	Taxable income report	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L35	Performance analysis	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L36	Performance reporting including risk analysis	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L37	Statutory accounts	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L39	Superannuation funds§	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
L40	Unit trusts§	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable

Table L.5: SAFE CUSTODY

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L41	Rental of safety deposit§ boxes	Section 9-5 40-5.12 Items 3 and 16	Taxable†	Not applicable
L42	Safe custody§ of money§, documents and other things	Section 9-5 40-5.12 Items 3 and 16	Taxable†	Not applicable

Table L.6: PERSONAL TRUST^§ AND PERSONAL SERVICES: LEGAL SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L44	Preparation of Power of Attorney§	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L45	Deed§ preparation	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L46	Will preparation	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L47	Applications for probate§	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L48	Applications for letters of administration	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table L.7: PERSONAL TRUST^§ AND PERSONAL SERVICES: TRUST AND ESTATE ADMINISTRATION SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L50	Trustee§ fee	Section 9-5 40-5.12 Item 15	Taxable†	The fee charged by the trustee§ will be taxable regardless of how it is calculated.
L51	Management fee§ charge for internal common funds§	See note	Varied See note	May vary depending on structure of internal common funds§ ; that is, whether the management services are supplies individually to each beneficiary or contributor to the common fund or to an entity being the trustee of the common fund. Subject to individual ATO decision (for example, private ruling).
L52	Fee for transferring intestate assets	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L53	Co-trustees commission§	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable

Table L.8: PERSONAL TRUST^§ AND PERSONAL SERVICES: PERSONAL SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L55	Fees for holding or managing capital assets on behalf of another entity	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
L56	Income commission§	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
L57	Third party cheque§ fees	Section 9-5	Taxable‡	Not applicable
L58	Initial and trailing commissions§	Section 9-5	Taxable‡	Not applicable
L59	Management fee§ charge for internal common funds§	See note	Varied See note	May vary depending on structure of internal common funds§. Subject to individual ATO decision (for example, private ruling) see Line No. L51.

Table L.9: PERSONAL TRUST^§ AND PERSONAL SERVICES: SERVICES TO INVESTMENT FUNDS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L61	Third party prospectus§ management fees§	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
L62	Application processing fee	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
L63	Initial or trailing commissions§	Section 9-5	Taxable‡	Not applicable

Table L.10: PERSONAL TRUST^§ AND PERSONAL SERVICES: PROVISION OF PROFESSIONAL SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L65	Directors fee	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L66	Secretarial fee	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L67	Registered office fee§	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L68	Taxation fee	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L69	Accountancy fee	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L70	Land tax return fee	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table L.11: PERSONAL TRUST^§ AND PERSONAL SERVICES: SERVICES PERFORMED BY STATUTORY TRUSTEE ORGANISATIONS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L72	Property inspection	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L73	Property valuation	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L74	Property management	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L75	Acting as Trustee§	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L76	Strata management	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table L.12: SUPERANNUATION TRUSTEE^§ SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L77	Trusteeship of corporate superannuation funds§	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L78	Trusteeship of Public Offer superannuation funds§	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L79	Manage investment strategy	Section 9-5 40-5.12 Items 3, 12 and 15	Taxable†	Not applicable
L80	Manage accounts and records	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L81	Prepare client statements	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L82	Document security	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L83	Act as approved trustee§	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L84	Collect and process dividends§ or interest	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L85	Effecting the transfer of title to securities§	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L86	Receive or take up entitlement issues	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L87	Purchase or sell investments	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L88	Record investments purchase or sale transactions	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L89	Reconcile bonus shares, rights issues, dividends§	Section 9-5 40-5.12 Items 12 & 15	Taxable†	Not applicable

Table L.13: CORPORATE SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L90	Compliance advice	Section 9-5 40-5.12 Items 3 and 15	Taxable†	Not applicable
L91	Prepare superannuation and taxation returns (including BAS)	Section 9-5 40-5.12 Items 3 and 15	Taxable†	Not applicable
L92	CHESS§ or CHAMP§ administration	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L93	Provide and confirm buy or sell instructions through CHESS§ or CHAMP§	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable
L95	Trustee§ services provided in acting as trustee§ for structured finance funds	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L96	Trustee§ services provided in acting as trustee§ of a unit trust§	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L97	Trustee§ services provided in acting as trustee§ of debenture§ and note issues	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L98	Trustee§ services provided in acting as trustee§ for security bonds	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L99	Trustee§ services provided in acting as trustee§ of a trust§ or other entity	Section 9-5 40-5.12 Item 15	Taxable†	Given as an example of item 15 in Schedule 3, clause 6, item 1.
L100	Trustee§ services provided in acting as trustee§ under a will or settlement§	Section 9-5 40-5.12 Item 15	Taxable†	Given as an example of item 15 in Schedule 3, clause 6, item 2.
L101	Trustee§ services provided in acting as mortgage§ custodian§	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
L103	Statutory accounts preparation	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L104	Compliance services§	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable
L105	Preparation of financial plans	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table L.14: SECURITISATION: SERVICES PROVIDED IN ACTING AS TRUSTEE^§ OVER A UNIT TRUST^§ STRUCTURE FOR MORTGAGE BACKED^§ AND ASSET BACKED^§ SECURITISATION^§ PROGRAMS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L107	Review of legal documentation	Section 9-5 40-5.12 Items 3 and 15	Taxable†	Not applicable
L108	Activity of acquiring title to mortgages§	Section 9-5 40-5.12 Item 15	Taxable†	This is distinct from gaining an interest in the mortgage§ as financial supply provider under table item 3 of section 40-5.09(3).
L109	Maintenance of trust§ bank accounts in the Trustee's name	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L110	Holding authorised investments in the Trustee's name	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L111	Maintaining trust§ ledger accounts in accordance with the Trust Deed§	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L112	Safekeeping of physical securities§ and documents evidencing title to assets and maintenance of electronic records or depository balances	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L113	Settling all funds received from the relevant assets in accordance with the Trust Deed§	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L114	Ensuring prompt payment to bondholders, either in certified form on a register or on a nominated depository	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L115	Appointing auditors	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable

Table L.15: SECURITISATION: SERVICES IN ACTING AS SECURITY TRUSTEE^§ FOR MORTGAGE BACKED AND ASSET BACKED SECURITISATION^§ PROGRAMS

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L117	Hold charge over assets of special purpose vehicle to secure payment to bondholders	Section 9-5 40-5.12 Item 15	Taxable†	The acquisition of the mortgage§ or charge over the assets of the special purpose vehicle by the security trustee§ (in their own right) may be a financial supply§ if the other requirements of section 40-5.09 are met.
L118	Acting as custodian§ of assets of special purpose vehicle	Section 9-5 40-5.12 Item 15	Taxable†	The acquisition of the mortgage§ or charge over the assets of the special purpose vehicle by the security trustee§ (in their own right) may be a financial supply§ if the other requirements of section 40-5.09 are met.
L119	Registrar services and maintenance of securities§ register	Section 9-5 40-5.12 Item 15	Taxable†	The acquisition of the mortgage§ or charge over the assets of the special purpose vehicle by the security trustee§ (in their own right) may be a financial supply§ if the other requirements of section 40-5.09 are met.

Table L.16: SECURITISATION: SERVICES IN ACTING AS BARE TRUSTEE^§ OR MORTGAGE^§ DOCUMENT CUSTODIAN^§

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L121	Holding documentation in safe custody§	Section 9-5 40-5.12 Items 15 and 16	Taxable†	Not applicable
L122	Input documentation on to document tracking system	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L123	Tracking relevant documents	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L124	Reviewing correctness of relevant documents	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L125	Obtaining approval from the beneficiary of the bare trust§ to execute or release documentation	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L126	Arranging for signatories to execute releases	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable
L127	Forwarding documentation to the appropriate party	Section 9-5 40-5.12 Item 15	Taxable†	Not applicable

Table L.17: SECURITISATION: OTHER

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L129	Fees and charges for coordinating the issue of debt securities§ by the special purpose vehicle	Section 9-5 40-5.12 Item 12	Taxable†	See Line No. D32.
L130	Fees and charges for servicing loan§ assets including loan management and debt§ collection services	Section 9-5 40-5.12 Items 12 and 13	Taxable†	Not applicable
L131	Fees and charges for the provision of liquidity facilities, swaps§, letters of credit and other financial accommodation	40-5.09(3) Items 2 and 11	Input taxed	Not applicable
L132	Fees and charges for the issue of debt§ or equity securities§ to investors	40-5.09(3) Item 10	Input taxed	Not applicable
L133	Rating services for securitisation§ vehicles	Section 9-5 40-5.12 Item 3	Taxable†	Not applicable

Table L.18: SECURITISATION: SECURITISATION^§ ARRANGEMENT

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
L135	Assignment§ of an income stream	40-5.09(3) Item 2	Input taxed	See Line No. D32.
L136	Issue of bond§ or debenture§	40-5.09(3) Item 10	Input taxed	See Line No. D33.
L137	Rating service§	40-5.09(3) Item 10	Input taxed	If the rating service is provided separately and constitutes an aim in itself, the supply will be taxable under item 3, section 40-5.12. See Line Nos. D34 and L133.

38. Table M. Summary of fees and services – Funds management

Omit the table, including the heading; substitute:

Summary of fees and services – Funds management

Table M.1: FUNDS MANAGEMENT

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
M1	Fees and charges for managing an asset portfolio or funds under management	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M2	Fees and charges for administration of an asset portfolio or funds under management	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M3	Acting as the trustee of an entity	Section 9-5 40-5.12 Items 12 and 15	Taxable†	Not applicable

Table M.2: FUNDS MANAGEMENT: INVESTMENT PORTFOLIO ADMINISTRATION SERVICES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
M5	Maintaining account holder records and associated accounting	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M6	Processing of contributions and returns	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M7	Storage and retrieval of archived documents	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M8	Statement processing and bulk mailing	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M9	Rental of safety deposit§ boxes	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable
M10	Clean payments made on behalf of another entity	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M11	Settling and undertaking of securities§ transactions at the direction of the custodian§ client	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M12	Collecting income and other payments with respect to the securities§ in the fund	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M13	Proxy voting§	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M14	Portfolio reporting – settlement§ activity, recurrent reporting	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M15	Option§ trading services performed on behalf of another entity	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M16	Fees charged by a funds manager for opening and maintaining bank accounts to facilitate settlement§ of security transactions	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M17	Safekeeping of physical securities§ and maintaining electronic records of depository balances	Section 9-5 40-5.12 Item 16	Taxable†	Not applicable

Table M.3: FUNDS MANAGEMENT: ACCOUNTING AND ADMINISTRATIVE SERVICES FOR FUNDS UNDER MANAGEMENT

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
M19	Maintenance of accounting records	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M20	Pricing of securities§	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M21	Taxation reporting	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M22	Mandate§ monitoring	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M23	Trade execution monitoring	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M24	Portfolio performance analysis	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable
M25	Risk management§ reporting	Section 9-5 40-5.12 Item 12	Taxable†	Not applicable

39. Table N. Summary of fees and services – Commodities and Collectibles

Omit the table, including the heading; substitute:

Summary of fees and services – Commodities and Collectibles

Note: Refer to Line Nos. H8 and H13 in relation to:

•

commodity derivatives involving no option, right or obligation to delivery

•

cash settled derivatives.

Table N.1: COMMODITIES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
N1	Purchase and sale of commodities	Section 9-5	Taxable†	Not applicable
N2	Deliverable wool futures and forward contracts§	Section 9-5 40-5.12 Item 7	Taxable†	Schedule 3, clause 3 item 1.
N3	Deliverable wheat futures and forward contracts§	Section 9-5 40-5.12 Item 7	Taxable†	Schedule 3, clause 3 item 2.
N4	Options§ over a deliverable wool future or forward contract§	Section 9-5 40-5.12 Item 7	Taxable†	Schedule 3, clause 3 item 3.
N5	Options§ over deliverable wheat futures and forward contracts§	Section 9-5 40-5.12 Item 7	Taxable†	Schedule 3, clause 3 item 3.

Table N.2: COLLECTIBLES

Line no.	Supply, service or consideration	GST Regulation or GST Act	GST status	Notes
N6	Collector's piece (other than precious metals§)	Section 9-5	Taxable‡	Excluded from the definition of money§ in section 195-1 of the GST Act and not included as a financial supply§ in any item under regulation.
N7	Investment articles (other than precious metals§)	Section 9-5	Taxable‡	Excluded from the definition of money§ in section 195-1 of the GST Act and not included as a financial supply§ in any item under regulation.
N8	Item of numismatic§ interest (other than precious metals§)	Section 9-5	Taxable‡	Excluded from the definition of money§ in section 195-1 of the GST Act and not included as a financial supply§ in any item under regulation.
N9	Currency the market value of which exceeds its stated value as legal tender in the country of issue (other than precious metals§)	Section 9-5 40-5.12 Item 17	Taxable†	Excluded from the definition of money§ in section 195-1 of the GST Act and not included as a financial supply§ in any item under regulation.

This Addendum applies from both before and after its date of issue.

Commissioner of Taxation
20 November 2024

© 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).

References

ATO references:
NO 1-W39TGPE

Business Line:  ISP