Private ruling: Financial supply of a credit arrangement
Date of advice: 8 October 2021
Published: December 2021

Ruling: Q1: Whether certain fees are consideration for an input taxed supply under A New Tax System (Goods and Services Tax) Act 1999 (GST Act) ? | A1: Yes. The fees are consideration for an input taxed financial supply under section 40-5 of the GST Act.

Relevant facts and circumstances: Entity A entered into a contract with Entity B to construct an infrastructure where payments were payable at different stages. The Entity A charged fees to Entity B to defer payment for each milestone payment.

Relevant legislative provisions: A New Tax System (Goods and Services Tax) Act 1999 Section 9-5 | A New Tax System (Goods and Services Tax) Act 1999 Section 40-5 | A New Tax System (Goods and Services Tax) Regulations 2019 Section 40-5