Private ruling: Currency swaps
Date of advice: 6 July 2018
Published: September 2018

Ruling: Q1: Is a supply via a swap of circulating coin an input taxed supply pursuant to section 40-100 of the GST Act? | A1: As a currency swap is at face value, the swap transaction is not a taxable supply, pursuant to subsection 9-10(4) of the GST Act . | Q2: Who hold legal title over the coins? | A2: As advised this is a contractual law matter that may only be determined by reviewing the relevant contracts. | Q3: Do you need to lodge one consolidated BAS with the ATO? | A3: As advised, this is not a question of law and it is an administrative matter for you to determine. Legislative provisions A New Tax System (Goods and Services Tax) Act 1999 subsection 9-10(4) A New Tax System (Goods and Services Tax) Act 1999 Subdivision 40-D