Private ruling: GST and Apportionment
Published: March 2014

Ruling: Q1: Is the revised apportionment methodology for the retail credit card business of Entity A, fair and reasonable for calculating the amount of input tax credits it is entitled to for its acquisitions, for the purposes of Division 11 and Division 15 of the A New Tax System (Goods And Services Tax) Act 1999 (the GST Act)? | A1: The Commissioner considers that the revised apportionment methodology for the retail credit card business of Entity A is, on balance, likely to provide a fair and reasonable basis for calculating the amount of input tax credits it is entitled to for its acquisitions for the purposes of Division 11 and Division 15 of the GST Act. | Q2: Can Entity A calculate and apply the revised apportionment methodology on an annual basis? | A2: Yes, Entity A can calculate and apply the revised apportionment methodology on an annual basis, provided this does not result in a distortion of the outcome. | Q3: Can Entity A implement its revised apportionment methodology with effect from a particular date? | A3: With the exception of one tax period, notification of which was not received within time, Entity A can implement its revised apportionment methodology with effect from the particular date provided all normal requirements of the ATO in relation to substantiation of the revised methodology are met.




Subject: GST and Apportionment: The ruling concerned the fair and reasonableness of an apportionment methodology and the Commissioner has ruled in the following way: