Private ruling: GST and the attribution rules
Date of advice: 7 September 2021
Published: November 2021
Ruling period: Year ending 30 June 20XX

Ruling: Q1: Is the GST payable on taxable insurance policies supplied by You attributable to the tax periods in which an instalment is paid for that policy pursuant to Division 156 of A New Tax System (Goods and Services Tax) Act 1999 (the GST Act)? | A1: Yes

Relevant facts and circumstances: You are registered for goods and services tax (GST) and account for GST on a non-cash (accruals) basis. You provide to your customers a number of general insurance products which are taxable supplies for GST purposes. The insurance contracts (policies) are normally entered into for a term of 12 months and are renewable annually, at the end of the term. In accordance with the Product Disclosure Statement (PDS) for an insurance policy, the policy holder has the option to pay the annual premium in one lump sum payment or elect to pay the premium by monthly instalments. For taxable insurance products which are paid by monthly instalments, the relevant tax invoice shows the period of insurance, the annual insurance premium amount, the GST payable on the premium, and the instalment amount of the premium per monthly period. You do not issue separate tax invoices for each instalment payment to the policy holder for taxable insurance policies where the premium is payable monthly.

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 subsection 29-5(1) | A New Tax System (Goods and Services Tax) Act 1999 section 29-39 | A New Tax System (Goods and Services Tax) Act 1999 Division 156 | A New Tax System (Goods and Services Tax) Act 1999 section 195-1


This ruling applies for the following period :