Private ruling: GST and medical aids and appliances
Date of advice: 30 January 2026
Published: 23 March 2026
Ruling period: XX/XX/20XX to XX/XX/20XX
Date scheme commenced: XX/XX/20XX

Ruling: Q1: Is your supply of the portable, standalone shower unit ('Shower Unit') GST-free under subsection 38-45(1) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) as a medical aid and appliance? | A1: No. Your supply of the Shower Unit is not GST-free under subsection 38-45(1) of the GST Act because it is not a medical aid and appliance covered by Schedule 3 to the GST Act, nor is it specified in section 38-45.01 of the A New Tax System (Goods and Services Tax) Regulations 2019 (GST Regulations).

Relevant facts and circumstances: You hold an Australian Business Number and GST registration. You supply the Shower Unit as part of your enterprise. The Shower Unit is a portable, standalone shower. You do not manufacture the Shower Unit.

Relevant legislative provisions: A New Tax System (Goods and Services Tax) Act 1999 section 38-45 | A New Tax System (Goods and Services Tax) Act 1999 section 182-10 | A New Tax System (Goods and Services Tax) Act 1999 section 182-15 | A New Tax System (Goods and Services Tax) Act 1999 schedule 3 | A New Tax System (Goods and Services Tax) Regulations 2019 section 38-45.01

Reasons for decision: Summary: A supply may be GST-free under subsection 38-45(1) of the GST Act if all of the following requirements are satisfied: 1. It must be covered by Schedule 3 to the GST Act or specified in the GST Regulations. 2. It must be specifically designed for people with an illness or disability. 3. It must not widely used by people without an illness or disability. | Detailed Reasoning - Covered by schedule 3 to the GST Act or specified in section 38-45.01 of the GST Regulations: To satisfy paragraph 38-45(1)(a) of the GST Act, an item must fall within a listed medical aid and appliance in Schedule 3 to the GST Act or subsection 38-45.01(1) of the GST Regulations. The principles for deciding whether a product falls within a listed medical aid and appliance in either table are set out in paragraph 3 of Goods and Services Tax Determination GSTD 2021/2 Goods and services tax: adjustable beds, pressure management mattresses and pressure management overlays (GSTD 2021/2). While the determination addresses specific bedding products, its reasoning applies to other products that may be GST-free under section 38-45 of the GST Act. It requires identifying the product's essential character by reference to its composition, function and other attributes. The essential character of the Shower Unit of a portable, standalone shower unit is not covered in Schedule 3 to the GST Act nor subsection 38-45.01(1) of the GST Regulations. Furthermore, we do not consider that Shower Unit is a 'shower support' under item 114 of Schedule 3 to the GST Act. Accordingly, paragraph 38-45(1)(a) of the GST Act is not satisfied. Although the Shower Unit is not covered by an item in Schedule 3 to the GST Act nor specified in section 38-45.01 of the GST Regulations, we have considered whether it is specifically designed for, and not widely used by, people without an illness or disability. | Detailed Reasoning - Specifically designed for people with an illness or disability: Our views on how to determine whether a product is specifically designed for people with an illness or disability and not widely used by people without an illness or disability are set out in GSTD 2021/2. Paragraph 7 of GSTD 2021/2 outlines non-exhaustive factors to consider when determining whether a product is specifically designed for people with an illness or disability. These include: • An objective view of the design features and characteristics of the product indicate whether its essential character is that it is specifically designed for people with an illness or disability. • The designer's or manufacturer's intention of how the particular product is to be used. Indicators of the designer's or manufacturer's intention include an objective consideration of how the product is marketed and the type of outlets at which the product can be purchased. The Shower Unit has features and characteristics that support the conclusion that it is specifically designed for people with an illness or disability. We therefore consider that it meets this requirement. | Detailed Reasoning - Not widely used by people without an illness or disability: Paragraphs 8 to 10 of GSTD 2021/2 provide our views on the 'not widely used' test. Whether a product is widely used by people without an illness or disability is a question of degree, informed by factors such as: • whether the product is widely sold in retail outlets that predominantly sell standard products to the general public; and • whether marketing material emphasises lifestyle benefits for people without an illness or disability. The Shower Unit is marketed in a way that emphasises features benefiting individuals with an illness or disability. It is not promoted as a general lifestyle product. Accordingly, we consider that the Shower Unit is not widely used by people without an illness or disability. | Detailed Reasoning - Conclusion: The Shower Unit is not GST-free as a medical aid and appliance under subsection 38-45(1) of the GST Act, as it is not covered by Schedule 3 to the GST Act nor the GST Regulations.