Private ruling: GST - importation of coins
Date of advice: 15 April 2026
Published: 29 June 2026
Ruling period: 1 July 20YY to 30 June 202YY
Date scheme commenced: 1 July 20YY

Ruling: Q1: Is the importation of coins (the coins) that were exported for grading services, considered as a non-taxable importation under section 42-10 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) when they are returned to Australia? | A1: Yes, the importation of the coins into Australia after the grading service is a non-taxable importation under section 42-10 of the GST Act as they will return to Australia in an unaltered condition.

Relevant facts and circumstances: You are an Australian resident. You collect xx coins for personal interest. You periodically send some of your coins overseas to a company located in the Country 1 for authentication and quality assessment. You are listed as the 'importer' of all coins returned to Australia. All coins involved in this request (the coins) were purchased in Australia and have been owned by you at all times. Under the grading service, the grading company does not physically change the coins condition/character in any way. They only authenticate the value of the coin. PCGS will then place the coin in a tamper-evident, sonically sealed acrylic plastic casing. The grading company then charges you a fee for this service. The coins are returned to you as the same Australian owner after the grading services are performed. Upon return to Australia, GST has been charged on the overseas grading service fees. Upon re-importation of the coins you were advised that you have been charged GST on the re-importation of the coins and will not allow you to claim a GST exemption on their shipment without a private ruling from the ATO. You acquired the coins as taxable supplies and were charged GST at the time of purchase. You were not entitled to, and did not claim, a payment related to the export of the coins from Australia, under the Tourist Refund Scheme (TRS).

Relevant legislative provisions: A New Tax System (Goods and Services Tax) Act 1999 section 13-5 | A New Tax System (Goods and Services Tax) Act 1999 section 13-10 | A New Tax System (Goods and Services Tax) Act 1999 section 42-5 | A New Tax System (Goods and Services Tax) Act 1999 section 42-10

Reasons for decision: Summary: Under section 13-5 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act), you make a taxable importation if: a) goods are imported; and b) you enter the goods for home consumption (within the meaning of the Customs Act 1901 ) However, the importation is not a taxable importation to the extent that it is a non-taxable importation. Goods and Services Tax Ruling GSTR 2003/15 Goods and services tax: importation of goods into Australia (GSTR 2003/15) provides guidance on the operation of the provisions in the GST Act which apply to the importation of goods into Australia. Goods are typically imported into Australia when they are brought to Australia to be unloaded or landed here. 'Imported' in this context has its ordinary meaning. Imported goods are considered for home use under the Customs Act when an 'owner' (as defined by the Act) submits an import declaration in their name. If you, as the 'owner', submit an import declaration in your name, you are responsible for paying GST on the import if it is taxable. If an agent submits the import declaration under the authority of the principal, the principal is responsible for the GST on the taxable import, not the agent. You will import the coins as the 'owner'. Therefore, both paragraphs (a) and (b) of section 13-5 of the GST Act are satisfied and your importation of the coins is a taxable importation unless the circumstances surrounding the importation make it a non-taxable importation. | Detailed Reasoning - Non-taxable importation: Under section 13-10 of the GST Act, an importation is a non-taxable importation if: a) it is a non-taxable importation under Part 3-2; or b) it would have been a supply that was GST-free or input taxed if it had been a supply. Section 42-5 of the GST Act deals with importation of goods that are non-taxable importations in accordance with specified items contained in Schedule 4 to the Customs Tariff Act 1995 (the Customs Act) . However, none of the specified items contained in Schedule 4 to the Customs Actwould apply to the reimportation of the coins in the circumstances described. There are no provisions in the GST Act under which the supply of the coins would be GST-free or input taxed. Therefore, the importation of the coins is not a non-taxable importation under paragraph 13-10(b) of the GST Act as the importation would not have been a GST-free or input taxed supply if it had been a supply. Section 42-10 of the GST Act provides that goods exported from Australia and returned to Australia in an unaltered condition, would be considered a non-taxable importation. Under subsection 42-10(1) of the GST Act, an importation of goods is non-taxable if: a) the goods were exported from the indirect tax zone and are returned to the indirect tax zone, without having been subject to any treatment, industrial processing, repair, renovation, alteration or any other process since their export; and b) the importer was not entitled to, and did not claim, a payment under Division 168 (about the tourist refund scheme) related to the export of the goods; and c) the importer: i. is the manufacturer of the goods; or ii. has previously acquired the goods, and the supply by means of which the importer acquired the goods was a taxable supply (or would have been a taxable supply but for section 66-45); or iii. has previously imported the goods, and the previous importation was a taxable importation in respect of which the GST was paid. In order for the coins to be a non-taxable importation under subsection 42-10(1) of the GST Act, you must satisfy paragraphs a; b; and c in subsection 42-10(1) of the GST Act. You satisfy paragraph 42-10(1)(b) of the GST Act as you were not entitled to, and did not claim, a payment under the Tourist Refund Scheme (TRS). You satisfy paragraph 42-10(1)(c) of the GST Act as you acquired the coins as a taxable supply to you and have paid GST. It remains to consider whether the importation of the coins meet paragraph 42-10(1)(a) of the GST Act. Are the coins returned to Australia without having been subject to any treatment, industrial processing, repair, renovation, alteration or any other process since their export? Goods and Services Tax Ruling GSTR 2005/2 Goods and services tax: supplies of goods and services in the repair, renovation, modification or treatment of goods from outside Australia whose destination is outside Australia (GSTR 2005/2) provides guidance on the meaning of repair, renovation, modification or treatment of goods. Paragraphs 34 to 42 of GSTR 2005/2 explain: The ordinary meaning of 'repair' is 'to restore to a good or sound condition after decay or damage; mend'. Repairing includes replacing defective or worn parts or re-attaching parts that have become detached. The ordinary meaning of 'renovate' is 'to make new or as if new again; restore to good condition; repair.' Renovation changes the character or enhances efficiency of function, while a repair merely restores the character or efficiency or function. The ordinary meaning of 'modify' is 'to change somewhat the form or qualities of; alter somewhat'. The ordinary meaning of 'treat' is to subject to some agent or action to bring about a particular result, for example, to treat a substance with an acid.' Processes such as cleaning, sterilising, waterproofing or rust proofing goods are examples of treating goods. The terms 'treating' and 'renovating' are limited to processes of the same kind of nature as repairing and modifying, neither of which contemplates the creation of completely new or different goods. Repair, renovation, modification or treatment is a process applied to existing goods which may involve some change in the nature, form or condition of the existing goods, the substance of which remains unchanged. That is, the essential or fundamental character of the goods is the same. The other goods retain their own identity. For the purposes of 'repair', Customs By-Laws No. 2300145 notes that 'repair' does not include repairs undertaken for the preservation or maintenance of goods. It is considered that the coins have been packaged for preservation, which does not otherwise alter the condition of the coins themselves. This as opposed to potentially changing the character of the coin to enhance its efficiency of function under the meaning of 'renovate'. It is viewed that the coins themselves have not enhanced in their efficiency of function as under the grading service, the coins remain unaltered and retain their own identity. Therefore, the coins which undergo only the grading service (and not any other additional services offered) will satisfy the requirements of paragraph 42-10(1)(a) of the GST Act and thus meet all of the requirements of subsection 42-10(1) of the GST Act and will be a non-taxable importation.