Private ruling: GST - membership
Date of advice: 7 July 2025
Published: 1 September 2025
Date scheme commenced: The date of issue of the ruling

Ruling: Q1: Are you making a taxable supply under section 9-5 of the A New Tax System (Goods and Service Tax) Act 1999 (GST Act) when you pass on to your members a payment request from an interstate sporting association for matches, they host where the payments are made by your members to an account nominated by the host association? | A1: No. | Q2: Are you making a taxable supply under section 9-5 of the GST Act when you collect payments from your members for entry fees on behalf of an interstate sporting association who are hosting a tournament, and you make a single payment of entry fees to that host association on behalf of your members? | A2: No. | Q3: Are you making a taxable supply under section 9-5 of the GST Act when you send teams to overseas competitions, and you collect the entry fees from your members and make a single payment to the overseas host? | A3: No. | Q4: Are you making a taxable supply under section 9-5 of the GST Act when you collect the annual membership fees from your members of $xx? | A4: Yes, you are making a taxable supply. Your GST liability is calculated as 1/11th of the consideration for the supply. The consideration for the supply of membership is $xx. The scheme commenced on: The date of issue of the ruling

Relevant facts and circumstances: You are registered for the goods and services tax (GST). You are a sporting association with members. An interstate sporting association hosts games and asks you to pass on their entry fee payment requests to your members who will then pay the entry fee to an account nominated by the interstate host. If an interstate sporting association organises games and charges an entry fee, they may ask you to collect the entry fees from your members and make a single payment to them. For providing this service to your members, you do not receive a fee from the interstate sporting association, nor do you retain any of the entry fees collected. You sometimes send teams to overseas competitions, and you collect and bank the fees from your members and send a single payment to the overseas host. You do not receive any payment from the overseas host nor retain any of the fees paid by your members, or separately charge your members for this service. Your members pay their annual membership fees of $xx to you via a payment platform. The payment platform keeps $XX.XX of the membership fee being their commission. You pay part of the membership fee you receive to another entity to assist them with paying their expenses.

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 9-10 | A New Tax System (Goods and Services Tax) Act 1999 section 9-15 | A New Tax System (Goods and Services Tax) Act 1999 section 9-17

Reasons for decision: Detailed Reasoning - Detailed reasoning: In this case, to answer the questions at issue it needs to be determined whether you are making taxable supply. Section 9-5 of the GST Act sets out the requirements that must be met for an entity to make a taxable supply. Section 9-5 of the GST Act states: (a) you make the supply for *consideration; and (b) the supply is made in the course or furtherance of an *enterprise that you *carry on; (c) the supply is *connected with the indirect tax zone; and (d) you are *registered, or *required to be registered for GST. However, the supply is not a *taxable supply to the extent that it is *GST-free or *input taxed. All the above requirements must be met for a supply you make to be taxable. Relevantly, to satisfy the first requirement in section 9-5 of the GST Act, an entity must first make a 'supply' for which payment is 'consideration'. | Detailed Reasoning - Supply: The definition of 'supply' is provided by section 9-10 of the GST Act, which includes 'any form of supply whatsoever', such as the 'supply of goods', or the 'supply of services', or 'a provision of advice or information', or 'an entry into...an obligation... 'to do anything' or any combination of any 2 or more of the matters referred to in subsection 9-10(2). Goods and Services Tax Ruling GSTR 2006/9 Goods and services tax: Supplies (GSTR 2006/9) provides the Commissioner's view regarding the meaning and characterisation of a supply. Paragraph 108 of GSTR 2006/9 provides that for the supply to be a taxable supply there must also be consideration and a sufficient nexus between the supply and the consideration. | Detailed Reasoning - Consideration: Consideration is defined in section 195-1 of the GST Act to mean 'any consideration within the meaning given by sections 9-15 and 9-17, in connection with the supply or acquisition'. Subsection 9-15(1) of the GST Act provides that consideration includes 'any payment, or any act or forbearance, in connection with a supply of anything' or 'in response to or for the inducement of a supply of anything'. | Detailed Reasoning - Question 1: In this circumstance, you are merely distributing payment requests from the interstate sporting association to your members for a competition organised by the interstate sporting association. You are not making a supply to the interstate sporting association. You also do not receive a payment or anything from the interstate sporting association when you distribute funds to them on request. Therefore, you are not making a taxable supply. | Detailed Reasoning - Questions 2 and 3: In these circumstances, you are making a supply of collecting and remitting your members payments to the interstate sporting association and overseas tournament organisers. You do not receive payment from the interstate sporting association or overseas tournament organiser. Accordingly, while you are making a supply it is not a 'supply for consideration' and therefore you are not making a taxable supply. | Detailed Reasoning - Question 4: Membership fees are payments in return for services or rights and are subject to GST where the entity is registered or required to be registered for GST. Membership bestows rights to members even where nothing tangible is supplied. An annual membership fee of $xx is payable by your members for the services you provide. To assist another entity, meet their expenses they have requested a fee from each player from related bodies including you. The funds paid by you to that entity comes out of the annual membership fees paid by your members. You end up with an amount less than the amount your members pay for membership after the payment platform takes their commission and you pay an amount to the other entity. Your GST liability is 1/11th of the amount paid by your members.