Class Ruling CR 2016/64
Date of effect: 1 July 2013

What this ruling is about: 1. This Ruling sets out the Commissioner's opinion on the way in which the relevant provisions identified below apply to the defined class of entities, who take part in the scheme to which this Ruling relates. Relevant provisions 2. The relevant provisions dealt with in this Ruling are: Unless otherwise stated, all legislative references are to the GST Act. Class of entities 3. The class of entities to which this Ruling applies is: Growers Qualifications 4. The Commissioner makes this Ruling based on the precise schemes identified in this Ruling. 5. The class of entities defined in this Ruling may rely on its contents provided the scheme actually carried out is carried out in accordance with the scheme described in paragraphs 9 to 33 of this Ruling. 6. If the scheme actually carried out is materially different from the scheme that is described in this Ruling, then:

Class of entities or scheme: 3. The class of entities to which this Ruling applies is: Growers | Qualifications: 4. The Commissioner makes this Ruling based on the precise schemes identified in this Ruling. 5. The class of entities defined in this Ruling may rely on its contents provided the scheme actually carried out is carried out in accordance with the scheme described in paragraphs 9 to 33 of this Ruling. 6. If the scheme actually carried out is materially different from the scheme that is described in this Ruling, then: 7. This Ruling applies from 1 July 2013. However, this Ruling will not apply to taxpayers to the extent that it conflicts with the terms of a settlement of a dispute agreed to before the date of issue of this Ruling (see paragraphs 75 and 76 of Taxation Ruling TR 2006/10). 8. The following description of the scheme is based on information provided by the applicant. | Overview: 9. Gunns Plantation Limited (Receivers and Managers Appointed)(Liquidators Appointed) ('GPL (LA)') as the responsible entity ('RE') for the GSP Schemes and GPLW Projects (collectively referred to as 'Schemes') is in liquidation, and therefore the Schemes are unable to continue to be operated. In winding up the Schemes, the Liquidators of GPL (LA) have completed (or are in the process of negotiating) a number of 'Sale Agreements' to sell the relevant Scheme Assets (predominantly the right, title and interest in the standing 'timber' ('Trees')). 10. The 'Sale Agreements' and the allocation of the relevant Sale Proceeds to each Scheme have been approved by the Court. As Scheme Members, Growers will be entitled to a distribution from the pool of the Net Liquidation Sale Proceeds attributable to their Scheme. GSP Schemes 11. The GSP Schemes comprises nine registered MISs [1] initially established and operated by Great Southern Managers Australia Limited (GSMAL), as the appointed RE under the Constitution that governs each GSP Scheme. In 2009, Gunns Plantations Limited (GPL) replaced GSMAL as the appointed RE for each of the GSP Schemes. 12. The GSP Schemes provided Growers with the opportunity to invest in hardwood timber plantations primarily located in Western Australia, Victoria, South Australia and Queensland. GPLW Projects 13. The GPLW Projects comprises seven registered MISs established and operated by GPL, as the RE appointed under the Constitution that governs each GPLW Project. The GPLW Projects provided Growers the opportunity to invest in Eucalyptus or Radiata Pine wood on woodlots located in Tasmania and the Southern Highlands region of New South Wales. | Project Documents: 14. Relevantly, the documents for the Schemes ('Project Documents') include the: 15. As there is no relevant material difference between the GSP Schemes and GPLW Projects in terms of how they were established and operated, the Project Documents relating to the Great Southern Plantation 2005 Scheme ('GSP 2005 Scheme') are referred to for description purposes. | GSP 2005 Scheme: Constitution 16. Relevantly, the terms of the GSP 2005 Scheme 'Constitution' provide for: Land and Management Agreement [2] 17. Upon sufficient subscriptions being reached, GSMAL used its power of attorney to execute the Land and Management Agreement. Under this agreement (entered into by GSMAL as the Landholder, GSMAL as RE, and the named Grower): Land Interest [3] 18. As required by the terms of the Land and Management Agreement, and within 9 months of entering into that agreement, GSMAL as Landholder grants the Grower a Lease of, or a Forestry Right over, the determined Woodlots upon the terms and conditions set out in the Land Interest (clause 2.2). 19. Relevantly, under a Land Interest involving the Lease of determined Woodlots (also referred to as a Sub-Lease): | Liquidation of the Schemes: 20. The Gunns Group of companies (including GPL) went into voluntary administration on 25 September 2012, and subsequently placed in liquidation on 5 March 2013. The resulting liquidation of GPL precipitated the winding up of the Schemes as the purpose of each Scheme could no longer be accomplished. 21. In realising the Scheme Assets, the Liquidators entered into negotiations with the owners of the 'Plantation Land' (being the land upon which GPL (LA) conducted the Schemes) for the sale of the right, title and interest in the 'Trees' situated on the 'Plantation Land'. 22. As the establishment and operation of each Scheme created rights in favour of both GPL (LA) and the Growers in relation to the 'Plantation Land', these rights had to be surrendered and extinguished in order for GPL (LA) to provide the respective 'Landowners' with clear title in the 'Trees'. 23. The Liquidators obtained Court approval on 31 May 2013 to procure GPL (LA) to amend the Schemes' Constitutions to provide it with the irrevocable power (as the agent, representative and attorney of the Grower) to unilaterally surrender and extinguish the Growers rights. 24. Through the unilateral exercise of this power, GPL (LA) entered into two major conditional 'Sale Agreements' with 'Landowners', namely: 25. In respect of the remaining part of the 'Plantation Land' used to conduct the Schemes, GPL (LA) has entered into / proposes to enter into a number of conditional 'Sale Agreements' with 'Third Party Landowners' (GSP / Gunns Third Party Landowner Agreements) for the sale of the right, title and interest in the 'Trees' situated on the Third Party Landowners' Land. The terms and conditions of these 'Sale Agreements' are essentially the same as those covered in the ASA. 26. While there are distinguishing features between the ASA and BSA [4] , these differences are not considered material. Consequently, for description purposes, the relevant ASA terms and conditions are referred to in this Ruling. ASA Terms and Conditions [5] 27. Relevantly, the terms and conditions of the ASA provide that: Surrender and Release Deed (Grower Lease and Instrument) (Deed)) [7] 28. Relevantly, the terms of the Deed for each Scheme provide that: | Court approval of the Sale Agreements and Sale Proceeds Allocation methods: 29. In satisfaction of the condition precedent stipulated by clause 2.1(b) of the ASA, the Liquidators obtained Court approval for the ASA on 16 December 2013. Furthermore, on 5 June 2014 the Court approved the method to allocate the net amount of the 'Sale Proceeds' to each GSP Scheme. 30. In respect of the other 'Sale Agreements': 31. In each case, the net amount of Sale Proceeds allocated to each Scheme is further reduced by the costs attributable to each Scheme to leave a 'Net Liquidation Sale Proceeds amount'. 32. Growers who are members of a Scheme have a right as against GPL (LA) to a distribution from the relevant Net Liquidation Sale Proceeds amount equal to their proportional interest in the Scheme. | Growers: 33. Growers are not making supplies for consideration for the purposes of paragraph 9-5(a) when GPL (LA) in its RE capacity: 34. As a result, Growers are not making taxable supplies under section 9-5 and therefore have no liability to pay GST under section 9-40 in respect of these transactions. Commissioner of Taxation 14 September 2016 35. Subsection 7-1(1) provides that GST is payable on taxable supplies. An entity makes a taxable supply where the requirements of section 9-5 are met. 36. An essential characteristic of a taxable supply is the test imposed by paragraph 9-5(a) which requires that a 'supply' be made for 'consideration'. Therefore, in satisfying this test, an entity needs to identify from a given transaction that: | Making a Supply: 37. For GST purposes, a 'supply' is broadly defined in subsection 9-10(1) as 'any form of supply whatsoever'. In terms of defining what constitutes the 'making of a supply', the High Court observed in Commissioner of Taxation v. MBI Properties Pty Ltd [9] that: | Consideration: 38. Under subsection 9-15(1), 'consideration' includes any payment in connection with, in response to or for the inducement of a 'supply'. | Sufficient Nexus: 39. In determining whether there is a 'sufficient nexus' between a 'supply' and 'consideration', the Commissioner identified in Goods and Services Tax Ruling GSTR 2006/9 [10] that: 40. Further, in identifying the character of the connection required by paragraph 9-5(a), the Commissioner states at paragraph 180B of GSTR 2006/9 that: | 'Forest Produce' sale transactions: 41. Scheme Assets predominantly consist of the 'Head-Leases' or 'Forestry Rights' over the 'Plantation Lands' (granted by the 'Landowners') and the 'Trees' grown on those Lands (which GPL (LA) as the RE of each Scheme holds on trust for the benefit of Scheme Members). Accordingly, the value of the 'Plantation Land' for the duration of the 'Planting Period' is naturally enhanced by the value of the standing 'Trees'. 42. However, the essence of each Scheme lies in the nature of the Agreements ('Land and Management Agreement' / 'Management Agreement' and 'Land Interest' documents) that the RE enters into with each Scheme Member (Grower). 43. Under these 'Agreements', entitlements are created in favour of the Grower in the form of: 44. By means of acquiring these rights as a participant in a Scheme, it is generally accepted for GST purposes that a Grower will satisfy the registration requirements imposed by section 23-10 being an 'entity' (within the meaning of section 184) that is 'carrying on an enterprise (within the meaning of section 9-20). 45. In other words, through the acquisition of 'Woodlot' interests and the 'Services' performed by GPL (LA), each Grower is viewed as carrying on an enterprise of commercial silviculture activities. Furthermore, the carrying on of this Grower enterprise is separate from the enterprise that GPL (LA) carries on in relation to the operation of each Scheme. 46. On this basis, in the normal course of the operation of a Scheme, it follows that by exercising its rights in relation to the harvesting and sale of its 'Woodlot Trees' ('Forest Produce'), each Grower is providing something of value to a recipient in the form of 'Forest Produce' which constitutes the 'making of a supply'. Furthermore, the making of such a supply would have a 'sufficient nexus' with a payment ('consideration') being the Grower's share of the net amount of Sale Proceeds that is deposited into the Proceeds Fund. 47. Therefore, in relation to the 'Forest Produce' sale transactions contemplated by the terms and conditions of the 'Project Documents', each Grower would satisfy the requirements of paragraph 9-5(a). In turn, this would result in the Grower making a 'taxable supply' of the 'Forest Produce' grown on their Woodlots under section 9-5 (where the further requirements of section 9-5 are met) and being liable for the GST payable under section 9-40. | 'Sale Agreement' Transactions: 48. By contrast, the circumstances surrounding the entry into the Sale Agreements (as evidenced by the Gunns Group going into liquidation and the various Court Orders) and the facts of the 'Sale Agreements' (as evidenced by the example of the ASA terms and conditions) demonstrate that the Growers are not 'making a supply' of their right, title and interest in the 'Trees' ('Forest Produce') to either the Buyer (in each case) or GPL (LA) in its RE capacity as part of these transactions. [11] 49. In particular, the circumstances surrounding the entry into the 'Sale Agreements' establish that: 50. The exercise of these 'powers' found expression in the form of the terms and conditions of the 'Sale Agreements' entered into between GPL (LA) in its RE capacity and the respective 'Landowners'. 51. In particular, and with regard to the example of the ASA entered into between GPL (LA) in its capacity as RE of the GSP Schemes (Seller) and the Buyer (being the owner of the GSP 'Plantation Land'), the following facts are established: 52. From these facts and circumstances it is firstly evident that the process to effect the surrender, release and relinquishment of a Grower's rights, title and interest in the 'Trees' (derived from the Grower's Sub-Lease of Woodlots) is manifestly different from the arrangements contemplated by the terms and conditions of the Project Documents to effect the sale of a Grower's 'Forest Produce'. 53. This difference is borne out by the fact that the 'Sale Agreement' process is entirely being driven by GPL (LA) acting in its RE capacity and in accordance with the irrevocable powers bestowed on it by virtue of the Constitutional amendments. 54. Consequently, it does not follow that a Grower should be viewed as 'making a supply' for the purposes of paragraph 9-5(a) under the terms and conditions of a 'Sale Agreement', because they would ordinarily be viewed as 'making a supply' under the terms and conditions of the 'Project Documents'. 55. It is further evident that the terms and conditions of the 'Sale Agreement' do not impose on Growers any particular obligations in terms of the disposal of their interests in the Trees. This is made clear by reference to the terms of the Deeds. Under these terms, GPL (LA), in accordance with its RE capacity powers, is unilaterally taking action to cede all of the 'Grower Rights' (in respect of a particular Scheme), which has the effect of vesting in it the Growers' rights, title and interest in the Trees. 56. This outcome is achieved under the terms of the Deeds without the Grower providing anything to GPL (LA) in its RE capacity, as the Grower takes no action to cause its legal interests to be transferred or surrendered. Furthermore, the terms of the Deeds do not place the Grower under any obligation to do anything, refrain from doing something or tolerate an act or situation. 57. It follows that the intended effect of these executed Deeds (delivered on Completion) is to momentarily ensure that GPL (LA's) rights, title and interest in the 'Trees' standing on the Buyer's 'Plantation Land' (Scheme Assets) is held free from the 'Growers' Rights', so that GPL (LA) in its RE capacity can discharge its obligations under clause 3 of the ASA. In doing so, subject to the surrender and release of its rights under the 'Head-Leases' / Forestry Right Deeds, it is GPL (LA) in its RE capacity, not each Grower, that is making a taxable supply of the rights, title and interest in the 'Trees' to each Buyer. | GPL (LA) in its RE capacity - not acting as agent for the Growers: 58. For completeness, the Commissioner considers that GPL (LA) in its RE capacity is not acting as the agent of the Growers when it discharges its obligations as a party to a 'Sale Agreement' or as a party to the 'Deeds'. While the Constitution powers bestowed on GPL (LA) in its RE capacity are expressed in agency-like terms, the context of the 'Sale Agreement' transactions informs the view that the exercise of these powers were not intended to effect agency relationships in the ceding of 'Grower Rights'. | Summary: 59. Growers are not making supplies for consideration for the purposes of paragraph 9-5(a) when GPL (LA) in its RE capacity disposes of 'Scheme Assets' to 'Buyers' in accordance with the terms and conditions of a 'Sale Agreement'. 60. As a result Growers are not making taxable supplies under section 9-5 and therefore have no liability to pay GST under section 9-40 in respect of a 'Sale Agreement' transaction. | Distribution of Net Liquidation Sale Proceeds to Growers: 61. By virtue of their interest in a particular Scheme, Growers will be entitled to a distribution from the pool of the 'Net Liquidation Sale Proceeds' arising from the completion of the related 'Sale Agreement'. 62. These distribution payments will be made by GPL (LA) to Growers as a consequence of their membership interests and without regard to any further act or entry into an obligation to do anything, refrain from doing something or tolerate an act or situation provided by the Growers. 63. Consequently, Growers will not be making supplies for consideration for the purposes of paragraph 9-5(a) when GPL (LA) in its RE capacity makes a payment to a Grower discharging their entitlement, to a distribution from the pool of the 'Net Liquidation Sale Proceeds'. 64. As a result Growers will not be making taxable supplies under section 9-5 and will therefore have no liability to pay GST under section 9-40 in respect of any such transactions. 65. The following is a detailed contents list for this Ruling: © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products). Not previously issued as a draft

Ruling: Growers: 33. Growers are not making supplies for consideration for the purposes of paragraph 9-5(a) when GPL (LA) in its RE capacity: 34. As a result, Growers are not making taxable supplies under section 9-5 and therefore have no liability to pay GST under section 9-40 in respect of these transactions. Commissioner of Taxation 14 September 2016


Appendix: 35. Subsection 7-1(1) provides that GST is payable on taxable supplies. An entity makes a taxable supply where the requirements of section 9-5 are met. 36. An essential characteristic of a taxable supply is the test imposed by paragraph 9-5(a) which requires that a 'supply' be made for 'consideration'. Therefore, in satisfying this test, an entity needs to identify from a given transaction that: | Making a Supply: 37. For GST purposes, a 'supply' is broadly defined in subsection 9-10(1) as 'any form of supply whatsoever'. In terms of defining what constitutes the 'making of a supply', the High Court observed in Commissioner of Taxation v. MBI Properties Pty Ltd [9] that: | Consideration: 38. Under subsection 9-15(1), 'consideration' includes any payment in connection with, in response to or for the inducement of a 'supply'. | Sufficient Nexus: 39. In determining whether there is a 'sufficient nexus' between a 'supply' and 'consideration', the Commissioner identified in Goods and Services Tax Ruling GSTR 2006/9 [10] that: 40. Further, in identifying the character of the connection required by paragraph 9-5(a), the Commissioner states at paragraph 180B of GSTR 2006/9 that: | 'Forest Produce' sale transactions: 41. Scheme Assets predominantly consist of the 'Head-Leases' or 'Forestry Rights' over the 'Plantation Lands' (granted by the 'Landowners') and the 'Trees' grown on those Lands (which GPL (LA) as the RE of each Scheme holds on trust for the benefit of Scheme Members). Accordingly, the value of the 'Plantation Land' for the duration of the 'Planting Period' is naturally enhanced by the value of the standing 'Trees'. 42. However, the essence of each Scheme lies in the nature of the Agreements ('Land and Management Agreement' / 'Management Agreement' and 'Land Interest' documents) that the RE enters into with each Scheme Member (Grower). 43. Under these 'Agreements', entitlements are created in favour of the Grower in the form of: 44. By means of acquiring these rights as a participant in a Scheme, it is generally accepted for GST purposes that a Grower will satisfy the registration requirements imposed by section 23-10 being an 'entity' (within the meaning of section 184) that is 'carrying on an enterprise (within the meaning of section 9-20). 45. In other words, through the acquisition of 'Woodlot' interests and the 'Services' performed by GPL (LA), each Grower is viewed as carrying on an enterprise of commercial silviculture activities. Furthermore, the carrying on of this Grower enterprise is separate from the enterprise that GPL (LA) carries on in relation to the operation of each Scheme. 46. On this basis, in the normal course of the operation of a Scheme, it follows that by exercising its rights in relation to the harvesting and sale of its 'Woodlot Trees' ('Forest Produce'), each Grower is providing something of value to a recipient in the form of 'Forest Produce' which constitutes the 'making of a supply'. Furthermore, the making of such a supply would have a 'sufficient nexus' with a payment ('consideration') being the Grower's share of the net amount of Sale Proceeds that is deposited into the Proceeds Fund. 47. Therefore, in relation to the 'Forest Produce' sale transactions contemplated by the terms and conditions of the 'Project Documents', each Grower would satisfy the requirements of paragraph 9-5(a). In turn, this would result in the Grower making a 'taxable supply' of the 'Forest Produce' grown on their Woodlots under section 9-5 (where the further requirements of section 9-5 are met) and being liable for the GST payable under section 9-40. | 'Sale Agreement' Transactions: 48. By contrast, the circumstances surrounding the entry into the Sale Agreements (as evidenced by the Gunns Group going into liquidation and the various Court Orders) and the facts of the 'Sale Agreements' (as evidenced by the example of the ASA terms and conditions) demonstrate that the Growers are not 'making a supply' of their right, title and interest in the 'Trees' ('Forest Produce') to either the Buyer (in each case) or GPL (LA) in its RE capacity as part of these transactions. [11] 49. In particular, the circumstances surrounding the entry into the 'Sale Agreements' establish that: 50. The exercise of these 'powers' found expression in the form of the terms and conditions of the 'Sale Agreements' entered into between GPL (LA) in its RE capacity and the respective 'Landowners'. 51. In particular, and with regard to the example of the ASA entered into between GPL (LA) in its capacity as RE of the GSP Schemes (Seller) and the Buyer (being the owner of the GSP 'Plantation Land'), the following facts are established: 52. From these facts and circumstances it is firstly evident that the process to effect the surrender, release and relinquishment of a Grower's rights, title and interest in the 'Trees' (derived from the Grower's Sub-Lease of Woodlots) is manifestly different from the arrangements contemplated by the terms and conditions of the Project Documents to effect the sale of a Grower's 'Forest Produce'. 53. This difference is borne out by the fact that the 'Sale Agreement' process is entirely being driven by GPL (LA) acting in its RE capacity and in accordance with the irrevocable powers bestowed on it by virtue of the Constitutional amendments. 54. Consequently, it does not follow that a Grower should be viewed as 'making a supply' for the purposes of paragraph 9-5(a) under the terms and conditions of a 'Sale Agreement', because they would ordinarily be viewed as 'making a supply' under the terms and conditions of the 'Project Documents'. 55. It is further evident that the terms and conditions of the 'Sale Agreement' do not impose on Growers any particular obligations in terms of the disposal of their interests in the Trees. This is made clear by reference to the terms of the Deeds. Under these terms, GPL (LA), in accordance with its RE capacity powers, is unilaterally taking action to cede all of the 'Grower Rights' (in respect of a particular Scheme), which has the effect of vesting in it the Growers' rights, title and interest in the Trees. 56. This outcome is achieved under the terms of the Deeds without the Grower providing anything to GPL (LA) in its RE capacity, as the Grower takes no action to cause its legal interests to be transferred or surrendered. Furthermore, the terms of the Deeds do not place the Grower under any obligation to do anything, refrain from doing something or tolerate an act or situation. 57. It follows that the intended effect of these executed Deeds (delivered on Completion) is to momentarily ensure that GPL (LA's) rights, title and interest in the 'Trees' standing on the Buyer's 'Plantation Land' (Scheme Assets) is held free from the 'Growers' Rights', so that GPL (LA) in its RE capacity can discharge its obligations under clause 3 of the ASA. In doing so, subject to the surrender and release of its rights under the 'Head-Leases' / Forestry Right Deeds, it is GPL (LA) in its RE capacity, not each Grower, that is making a taxable supply of the rights, title and interest in the 'Trees' to each Buyer. | GPL (LA) in its RE capacity - not acting as agent for the Growers: 58. For completeness, the Commissioner considers that GPL (LA) in its RE capacity is not acting as the agent of the Growers when it discharges its obligations as a party to a 'Sale Agreement' or as a party to the 'Deeds'. While the Constitution powers bestowed on GPL (LA) in its RE capacity are expressed in agency-like terms, the context of the 'Sale Agreement' transactions informs the view that the exercise of these powers were not intended to effect agency relationships in the ceding of 'Grower Rights'. | Summary: 59. Growers are not making supplies for consideration for the purposes of paragraph 9-5(a) when GPL (LA) in its RE capacity disposes of 'Scheme Assets' to 'Buyers' in accordance with the terms and conditions of a 'Sale Agreement'. 60. As a result Growers are not making taxable supplies under section 9-5 and therefore have no liability to pay GST under section 9-40 in respect of a 'Sale Agreement' transaction. | Distribution of Net Liquidation Sale Proceeds to Growers: 61. By virtue of their interest in a particular Scheme, Growers will be entitled to a distribution from the pool of the 'Net Liquidation Sale Proceeds' arising from the completion of the related 'Sale Agreement'. 62. These distribution payments will be made by GPL (LA) to Growers as a consequence of their membership interests and without regard to any further act or entry into an obligation to do anything, refrain from doing something or tolerate an act or situation provided by the Growers. 63. Consequently, Growers will not be making supplies for consideration for the purposes of paragraph 9-5(a) when GPL (LA) in its RE capacity makes a payment to a Grower discharging their entitlement, to a distribution from the pool of the 'Net Liquidation Sale Proceeds'. 64. As a result Growers will not be making taxable supplies under section 9-5 and will therefore have no liability to pay GST under section 9-40 in respect of any such transactions.


What this Ruling is about | NOT LEGALLY BINDING SECTION: | A public ruling is an expression of the Commissioner's opinion about the way in which a relevant provision applies, or would apply, to entities generally or to a class of entities in relation to a particular scheme or a class of schemes. | If you rely on this ruling, the Commissioner must apply the law to you in the way set out in the ruling (unless the Commissioner is satisfied that the ruling is incorrect and disadvantages you, in which case the law may be applied to you in a way that is more favourable for you - provided the Commissioner is not prevented from doing so by a time limit imposed by the law). You will be protected from having to pay any underpaid tax, penalty or interest in respect of the matters covered by this ruling if it turns out that it does not correctly state how the relevant provision applies to you. | 34. The concept of supply employed in the GST Act is of wide import. Absent modification of the general operation of the GST Act through application of a special rule, there is a supply whenever one entity (the supplier) provides something of value to another entity (the recipient)... | ..., the word 'for' ensures that not every connection between supply and consideration meets the requirements for a taxable supply. That is, merely having any form of connection of any character between a supply and payment of consideration is insufficient to constitute a taxable supply. (Footnote omitted) | Appendix 2 - Detailed contents list


Related rulings: TR 2006/10 GSTR 2006/9 CR 2016/19
Legislative references: ANTS(GST)A 1999 9-5 ANTS(GST)A 1999 9-10 ANTS(GST)A 1999 9-15 Corporations Act 2001 9 TAA 1953
Case references: Commissioner of Taxation v. MBI Properties Pty Ltd [2014] HCA 49 2014 ATC 20-474 (2014) 92 ATR 241
Other references: ATO ID 2010/196 ATO ID 2010/197 ATO ID 2010/198 ATO ID 2010/199