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1 Is your supply of digital content to recipients (subscribers and fans) in Australia through a non-resident internet subscription service platform, a taxable supply under section 9-5 of the A New Tax System (Goods and Services Tax) Act 1999 ?

1 Yes Question 2 Is your supply of digital content to non-resident recipients (subscribers and fans) outside Australia through a non-resident internet subscription service platform, a GST-free supply under table item 2 of subsection 38-190(1) of the A New Tax System (Goods and Services Tax) Act 1999 ? Answer 2 Yes Question 3 Is your supply of digital content to a non-resident video streaming platform a GST-free supply under table item 2 of subsection 38-190(1) of the A New Tax System (Goods and Services Tax) Act 1999 ? Answer 3 Yes Question 4 Is your supply of digital content to a non-resident social media platform a GST-free supply under table item 2 of subsection 38-190(1) of the A New Tax System (Goods and Services Tax) Act 1999 Answer 4 Yes This ruling applies for the following 1 July 2025 - 30 June 2025:

•                You, an Australian resident, are carrying on an enterprise of creating and providing digital content and are registered for goods and services tax (GST). •                You produce and distribute digital content through 3 non-resident platforms: o        An internet subscription service o        A video streaming platform o        A social media platform Internet Subscription Service •                This platform facilitates creator interaction where you as a creator supply content directly to the subscribers/fans. •                The subscribers/fans pay the platform for their purchase of your content and the platform collects the payments on your behalf. •                This platform transfers the payments collected to your bank account after deducting its fees for the use of its platform by the content creators and for storing the content. •                The platform does not collect the GST on behalf of the Australian content creators, and it does not charge GST on the fees charged by it to the content creators. •                The platform does collect the details of the purchasers based on their geolocation. Video Streaming Service

•                To be monetised through the video streaming service you need to enter into an agreement with it to permit it to play advertisements and other content in your videos. •                Subject to the terms of service agreement you have entered into, you receive a payment related to the number of valid clicks on ads displayed on any valid events performed in connection with the display of ads on your video. •                The video streaming service determines the location of the viewer and then plays the ad that is relevant to them in their country. Social Media Platform •                In order to monetise your content on the social media platform you must satisfy the platforms monetization policies. •                Pursuant to these policies, you grant the social media platform a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use your digital content. •                You receive payments from the social media platform based on a revenue share of payments received from viewers of your content from or a bonus payout based on the amount of reach, reactions, shares and comments on eligible social media posts.

A New Tax System (Goods and Services Tax) Act 1999 section 9-5 A New Tax System (Goods and Services) Act 1999 section 9-25 A New Tax System (Goods and Services) Act 1999 section 38-190

The supply of digital content by you to recipients (subscribers and fans) in Australia through a non-resident internet subscription service platform operator will satisfy all of the requirements of a taxable supply under section 9-5 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act). The supply of digital content by you to recipients (subscribers and fans) outside Australia through a non-resident internet subscription service platform will satisfy all of the requirements to be GST-free under table item 2 of subsection 38-190(1) of the GST Act. The supply of digital content by you to a non-resident video streaming platform operator) will satisfy all of the requirements to be GST-free under table item 2 of subsection 38-190(1) of the GST Act. The supply of digital content by you to a non-resident social media platform operator will satisfy all of the requirements to be GST-free under table item 2 of subsection 38-190(1) of the GST Act. Detailed reasoning A supply is defined in subsection 9-10(1) of the GST Act as "any form of supply whatsoever" and includes: (a)           a supply of goods; (b)           a supply of services;

(c)            a provision of advice or information; (d)           a grant, assignment or surrender of real property; (e)           a creation, grant, transfer, assignment or surrender of any right; (f)             a financial supply; (g)           an entry into, or release from, an obligation: i.                  to do anything; or ii.                  to refrain from an act; or iii.                  to tolerate an act or situation; (h)   any combination of any 2 or more of the matters referred to in paragraphs (a) and (g). The definition of supply is extremely broad. Goods and Services Tax (GST) is payable on a taxable supply. Under section 9-5 of the A New Tax System (Goods and Services Tax) Act 1999 , you make a taxable supply if: (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; and (c) the supply is connected with the indirect tax zone (Australia); and (d) you are registered or required to be registered for GST. However, a supply is not a taxable supply to the extent that it is GST-free or input taxed.

You are carrying on an enterprise of supplying digital content through online platforms. You receive consideration for your supply and you are registered for GST. One of the requirements of a taxable supply is that the supply should be connected with the indirect tax zone (Australia). Subsection 9-25(5) of the GST Act provides that a supply of anything other than goods or real property is connected with Australia if: (a) the thing is done in Australia; or (b) the supplier makes the supply through an enterprise that the supplier carries on in Australia; or (c) all of the following apply: i. neither paragraph (a) nor (b) applies in respect of the thing; ii. the thing is a right or option to acquire another thing; iii. the supply of the other thing would be connected with Australia; or (d) the recipient of the supply is an Australian consumer. To satisfy whether your supply of content will be connected with Australia, you need to meet one of the listed elements in subsection 9-25(5) of the GST Act. Since you make the supply through your enterprise carried on in Australia, your supply will satisfy paragraph 9-25(5)(b) of the GST Act.

Supply of content to fans and not to Internet Subscription Service Platform You supply content to recipients (fans and subscribers) based both in Australia and outside Australia. The internet subscriptions service platform's terms of service outline several agreements/contracts particularly the terms of use and the contract between fan and creator. The contract between fan and creator confirms that that each interaction between is between a fan and a creator and that the internet subscription service platform is not part of this agreement. The internet subscription service platform facilitates the transaction between you and the subscribers/fans by providing the platform, collecting payments, and deducting its fees. Based on the terms of the service, it is our view that you do not make your supply of content to the internet subscription service platform, rather you make the supply directly to your fans using the internet subscription service platform on the terms of the contract between fan and creator as explained above.

The supplies made to fans in Australia will satisfy all of the requirements of section 9-5 of the GST Act as the supplies are connected with Australia and therefore those supplies will be subject to GST. The supply of content will not be an input taxed supply under the GST provisions. However, the supply of content made to subscribers/fans outside Australia may satisfy the GST-free provisions. GST-free supply of content Subsection 38-190(1) of the GST Act provides that the supplies of things other than goods or real property for consumption outside of Australia will be GST-free. Table item 2 of subsection 38-190(1) of the GST Act provides that a supply that is made to a non-resident who is not in Australia when the thing supplied is done is GST-free where: (a) the supply is neither a supply of work physically performed on goods situated in Australia when the work is done, nor a supply directly connected with real property situated in Australia; or (b) the non-resident acquires the thing in carrying on the non-resident's enterprise but is not registered or required to be registered.

Your supply of content provided to non-resident subscribers/fans outside Australia is neither supply of work physically performed on goods located in Australia nor the supply connected with real property situated in Australia. Hence, your supply of content will satisfy the requirements of paragraph (a) in table item 2 of subsection 38-190(1) of the GST Act. Supply of content to Video Streaming Service You supply content to a video streaming service. To receive consideration for the supply of this content you need to accept the online monetisation terms of service. When you enter into this agreement your contract is with the non-resident video streaming service. In accordance with the terms of service you provide the video streaming service permission to do what is required to place advertisements on your videos. Further you grant the service the right to index and cache the properties etc. of your videos. You receive a payment related to the number of valid events performed in connection with the display of ads on your videos.

Based on the terms of the service, it is our view that you make your supply of content to the non-resident video streaming service and when you monetise your content you are receiving consideration from the non-resident video streaming service. Supply of content to Social Media Platform You supply content to a social media platform. To receive consideration for the supply of this content you need to agree to the platform's monetisation policies. In your agreements with the platform, you provide a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license in relation to your content. Furthermore, you receive a revenue share on the income that the social media platform receives in relation to your supply. You also receive payments based on the amount of reach, reactions, shares and comments on eligible posts. Based on the relevant terms, it is our view that you make your supply of content to the non-resident social media platform and when you monetise your content you are receiving consideration from the non-resident social media platform. GST-free supply of content

Subsection 38-190(1) of the GST Act provides that the supplies of things other than goods or real property for consumption outside of Australia will be GST-free. Table item 2 of subsection 38-190(1) of the GST Act provides that a supply that is made to a non-resident who is not in Australia when the thing supplied is done is GST- free where: (a) the supply is neither a supply of work physically performed on goods situated in Australia when the work is done, nor a supply directly connected with real property situated in Australia; or (b) the non-resident acquires the thing in carrying on the non-resident's enterprise but is not registered or required to be registered. Both your supply of content provided to the video streaming service and the social media platform is neither supply of work physically performed on goods located in Australia nor the supply connected with real property situated in Australia. Hence, your supply of content will satisfy the requirements of paragraph (a) in table item 2 of subsection 38-190(1) of the GST Act. As such the supplies you make to the video streaming service and the social media platform are a GST-free supply.