Private ruling: GST apportionment methodology
Published: June 2013

Ruling: Questions and Answers | 1. Is the methodology considered to be fair and reasonable for calculating extent of creditable purpose for acquisitions made by members of the Group for the purposes of Division 11 of the GST Act? | Yes, based on the facts as set out in this private ruling, the methodology is considered to be fair and reasonable for calculating extent of creditable purpose for acquisitions made by members of the Group that are not directly attributable to particular supplies for the purposes of Division 11 of the GST Act. | (All further legislative references are to GST Act unless stated otherwise) | (All further references to acquisitions made by you are to acquisitions made by members of the GST Group to which you act as Group representative) | 2. In the event that availability of information or business reporting varies such that a particular data source is no longer available, will the methodology remain fair and reasonable if a reasonable alternative data source is substituted? | In the event that availability of information or business reporting varies such that a particular data source is no longer available and a reasonable alternative data source is substituted, the methodology will remain fair and reasonable if the methodology continues to satisfy the requirements set out at paragraph 73 of GSTR 2006/3. | 3. Will the methodology remain fair and reasonable if it is applied for tax periods over a certain period in the past (the refund period)? | The methodology will remain fair and reasonable for all tax periods within the refund period if the circumstances for all tax periods within the refund period are materially identical to the circumstances set out in this private ruling. | 4. If data in relation to underlying drivers, such as business reports, are (sic) not available for prior years, is it fair and reasonable to use available information for other years during the refund period to generate alternate drivers provided that there is no available evidence of substantial distortion in result occurring? | If data in relation to underlying drivers, such as business reports, is not available for prior years, and you use available information for other years during the refund period to generate alternate drivers, the methodology will remain fair and reasonable if: | · your circumstances for the prior years (in respect of which data in relation to underlying drivers is not available) are materially identical to the circumstances of the other years during the refund period (in respect of which information is available) which years are also materially identical to the circumstances set out in this private ruling; and | · the methodology continues to satisfy the requirements set out at paragraph 73 of GSTR 2006/3.