Private ruling: : GST - course materials
Date of advice: 2 February 2026
Published: 30 March 2026

Ruling: Q1: Are you making a GST-free supply under section 38-95 of the A New Tax System (Goods and Services Tax) Act 1999 when it supplies photocopies of books and other written materials to students? | A1: Yes, providing photocopies of books and other written materials to students as part of course materials is GST-free under section 38-95 of the GST Act. | Q2: Are you making a GST-free supply under section 38-85 of the A New Tax System (Goods and Services Tax) Act 1999 when it supplies access to the online system to students? | A2: The supply of access to the online system is GST-free as the supply is part of the supply of an education course. | Q3: Are you making a GST-free supply under section 38-95 of the A New Tax System (Goods and Services Tax) Act 1999 when it supplies food ingredients to students undertaking culinary and kitchen management courses? | A3: Yes, providing food ingredients to students enrolled in culinary and kitchen management courses as part of course materials is GST-free under section 38-95 of the GST Act. | Q4: Are you making a GST-free supply under section 38-95 of the A New Tax System (Goods and Services Tax) Act 1999 when it provides cling wrap; disposable gloves; disposable piping bags; floor cleaning detergent; clothes washing laundry capsules; and garbage bags? | A4: Yes, providing cling wrap; disposable gloves; disposable piping bags; floor cleaning detergent; clothes washing laundry capsules; and garbage bags to students as part of course materials is GST-free under section 38-95 of the GST Act.

Relevant facts and circumstances: You are a registered training organisation (RTO) under the National Vocational Education and Training Regulator Act 2011 . You are registered for GST with effect from xx June 20xx and commenced membership in a GST Group effective xx April 20xx with xxx acting as the group representative. Prior to xx April 20xx, you were a member of a different GST Group with xxx. You provide educational courses to students, which are delivered and undertaken within Australia. The training courses you provide fall within the definition of an 'education course' as set out in section 195-1 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act). Examples include adult and community education courses, English language courses, and tertiary courses. A 'tertiary course' encompasses a course of study or instruction that has been determined by the Student Assistance Minister under subsection 5D (1) of the Student Assistance Act 1973 for the purposes of that Act. You provide your education courses through xxx colleges which are recognised with Australia's National Training Register. You provide students with photocopies of books and other written materials - these are prepared especially for and relate directly to each course. You print or photocopy written materials which are used by students to complete exercises, write on them and work through whilst undertaking the course. You provide access to digital materials (online notes, modules) via a learning management system xx. Students use the online system to engage with these materials by reading, viewing content, completing quizzes, submitting assignments, and adding annotations. Access to online system provided to each student is limited to the duration of the course. In addition to the course tuition fees, you charge students a separate fee for access to online system. The fee for online system is included in the course materials fee that is charged to student. Students undertaking culinary and kitchen management classes cook, prepare and taste food. You provide ingredients to the students during the course which are used in the practical classes. You provide cling film for use by students during culinary classes in the preparation and storage of food. The cling film is discarded after use. You make available disposable gloves to be used during practical lab classes for hospitality and aged care students. The gloves are used during the practical lessons and are disposed of after use. You provide disposable piping bags for use in culinary classes to prepare foods. These are essential for the practical component of food preparation. They cannot be reused and are disposed of after use. You supply floor-cleaning detergent and laundry capsules for students to use when cleaning the kitchen and related accessories during practical classes. You provide garbage bags for use by students in cleaning the kitchen and associated accessories during practical classes. These are single-use items and are discarded after use.

Relevant legislative provisions: A New Tax System (Goods and Services Tax) Act 1999 section 38-95 | A New Tax System (Goods and Services Tax) Act 1999 section 195-1

Reasons for decision: Summary: You provide photocopies of books and other written materials to students for use during the course. The photocopies are physically printed by you. The content of some handouts is created by you while some are photocopies from other resources. The photocopies may be written on and may contain worksheets and, as such, are necessarily consumed or transformed by the students undertaking the course. The photocopies are used for the purposes of the GST-free educations courses. Consequently, your supplies of photocopies to students as part of a GST-free education courses satisfy the requirements of course materials and are GST-free under section 38-95 of the GST Act. You provide students with access to the online xx system for use during the completion of an education course. xx is an online leaning management system that allows students to read course documentation; submit assignments; undertake quizzes, etc. As explained in paragraph 57-59 of GSTR 2001/1, the supply of facilities that are required for the delivery of an education course is GST-free as the facilities are part of the supply of the education course, it is irrelevant whether the amount charged for the supply of facilities is included in the fee you charge for the course or whether it is charged separately. Paragraph 59 of GSTR 2001/1 provides examples of supplies which are facilities: Paragraph 59 states: Facilities include such items as (a) the provision and maintenance of plant, equipment, buildings and grounds; (b) access to libraries including the access to library books, periodicals and manuals; (c) access to computer and science laboratories; (d) access to computers and other online resources including off campus dial up Internet services. The supply of access to the online system is covered by paragraph (d) as 'access to online resources' and, as such is GST-free under section 38-85 of the GST Act as part of the supply of the education course. You supply ingredients to students undertaking hospitality courses. The ingredients are necessarily consumed or transformed during by the students for the purposes of the course. As such, the ingredients satisfy the definition of course materials. This is confirmed at paragraph 84 of GSTR 2001/1 which states 'ingredients used in a hospitality course...' are 'examples of course materials when supplied by the educational institution'. Your supply of ingredients to students undertaking hospitality courses are GST-free under section 38-95 of the GST Act. Please note that this excludes utensils and other items; it applies solely to food ingredients. You provide the following consumables to students who are undertaking various courses: • Cling wrap/film • Disposable gloves • Disposable piping bags • Floor cleaning detergent • Clothes washing laundry capsules • Garbage bags As discussed above, your supplies of goods are GST-free under section 38-95 of the GST Act where the items are provided by you to students and the items are necessarily consumed or transformed by the students for the purposes of the GST-free course. Cling wrap/ film Cling wrap is utilised in culinary classes for the preparation and storage of food and is specifically required for the practical component of hospitality and food preparation courses. It is a single-use item, cannot be reused, and is discarded after use. The supply of cling wrap is essential for students to undertake the course and is consumed during the course. Therefore, the supply satisfies the definition of course materials. As such, the supply of cling wrap is GST-free under section 38-95 of the GST Act. Disposable gloves Disposable gloves are required for specific tasks undertaken during aged care practical classes to ensure hygiene and safety. These gloves are single-use items, cannot be reused, and are discarded after use. The supply of disposable gloves is essential for students to undertake the course and, therefore, satisfies the definition of course materials. As such, the supply of disposable gloves is GST-free under section 38-95 of the GST Act. Disposable Piping Bags Disposable piping bags are utilised in culinary classes for food preparation and are specifically required for the practical component of the course. These items are single use, cannot be reused, and are discarded after use. The supply of disposable piping bags is essential for students to undertake the course are consumed during the course. Therefore, the supply satisfies the definition of course materials. As such, the supply of disposable piping bags is GST-free under section 38-95 of the GST Act. Floor cleaning detergent and Clothes washing laundry capsules Floor cleaning detergent and clothes washing capsules are used by students to clean kitchens and associated accessories during practical classes. These products are essential materials for students undertaking the course. This is because the course includes units of competencies which include instruction of proper cleaning techniques and processes. The supply of these cleaning products is essential for students to undertake the course and are consumed during the course. Therefore, the supply satisfies the definition of course materials. As such, the supply of these cleaning products is GST-free under section 38-95 of the GST Act. Garbage bags Garbage bags are essential for completion of courses which include, for example, units of competency which include instruction of proper waste disposal and hygiene techniques and processes. The supply of garbage bags is essential for students to undertake the course and are consumed during the course. Therefore, the supply satisfies the definition of course materials. As such, the supply of disposable gloves is GST-free under section 38-95 of the GST Act.

Reasons for decision: Under section 38-95 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act), a supply of 'course materials' for a subject undertaken in an 'education course' is GST-free. | The term 'course materials' is defined in section 195-1 of the GST Act as 'materials provided by the entity supplying the course that are necessarily consumed or transformed by the students undertaking the course for the purposes of the course'. | Paragraphs 83 of the goods and services tax ruling, GSTR 2001/1 Goods and services tax: supplies that are GST-free for tertiary education courses (GSTR 2001/1) explains that materials or items will be course materials if all of the following requirements are met: | • the materials or items are provided by you to students; and | • the materials are necessarily consumed or transformed by the students undertaking the course; and | • the materials are consumed or transformed for the purposes of the course. | Paragraphs 100 and 101 of GSTR 2001/1 discuss the terms consumed and transformed: | 100. The term 'consumed' means destroyed or expended by use; used up. In the definition of course materials, 'consumed' is qualified by the requirement that it be '... by students undertaking the course for the purposes of the course'. So, if in undertaking a subject in an education course, a student uses up or expends materials, the student has consumed course materials. For example, the supply of a workbook that requires the student to complete exercises in it is a course material and therefore is GST-free. Chemicals that are used to develop photographic film also satisfy the definition of course materials because they are consumed in the process. These chemicals are also GST-free. | 101. The term 'transformed' means changed in form; changed to something of a different form; or changed in appearance, condition, nature or character, especially where the change is complete or extensive. It has also been defined to mean 'to change in character or condition; to alter in function or nature'. Examples of materials that are changed in form include cooking ingredients in a hospitality course, wood in a cabinet making course or photographic paper in a photography class. | Paragraphs 102 of GSTR 2001/1 provides the meaning of 'for the purpose of the course' | 102. Course materials are only those materials that are necessarily consumed or transformed by the students undertaking the course for the purpose of the course. 'Purpose' is defined to mean 'the object for which anything exists or is done, made, used, etc' or 'an intended or desired result; end or aim'. For the purposes of the Act, only those materials listed by you as being necessary for a particular course or subject are GST-free. Only those consumable stationery items that are required to undertake the course, that are listed on a book list, are GST-free. Any replacement on a reasonable basis of an item listed on a book list will also be GST-free. | Paragraph 84 of GSTR 2001/11 mentions that the following (among other things) are examples of course materials when supplied by the educational institution as part of a GST-free education course: | • photocopied or printed educational materials that specifically relate to the course; | • course notes for a specific subject outlining the course contents, reading lists, tutorial and seminar topics, assignment and essay questions; | • a study guide consisting of a collection of materials extracted from textbooks, journals and other reading materials including notes of the lecturer; | • workbooks that provide space for students to complete exercises. | • consumable stationery items specified by you that are necessary for students to undertake the course...