Issue
Is the entity, a supplier of farm machinery, issuing a tax invoice that meets the requirements under subsection 29-70(1) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) when it issues an invoice for a taxable supply made to more than one recipient?
Decision
Yes, the entity is issuing a tax invoice that meets the requirements under subsection 29-70(1) of the GST Act, when it issues an invoice for a taxable supply made to more than one recipient.
Facts
The entity is a farm machinery supplier. The entity makes a supply of a tractor to a father and son. The total price for the supply is greater than $1000 (including GST). The father and son purchase the tractor jointly for use in their separate businesses. The entity issues one invoice which includes the identities of both recipients. All of the other requirements for a document to be a tax invoice under subsection 29-70(1) of the GST Act are satisfied.
The supply is a taxable supply under section 9-5 of the GST Act. The entity is registered for goods and services tax (GST).
Reasons for Decision
Subsection 29-70(1) of the GST Act specifies the requirements for a document to be a tax invoice, including the information which must be able to be clearly ascertained from the document. Subsection 29-70(2) of the GST Act specifies that a tax invoice must be issued by the supplier for a taxable supply if requested by the recipient unless it is a recipient created tax invoice.
In this case, although there is more than one recipient, the entity is making a single taxable supply. The entity may issue a single tax invoice. As the total price for the supply is at least $1000, one of the requirements for a document to be a tax invoice is that the identity or ABN of the recipient must appear on the tax invoice (subparagraph 29-70(1)(c)(ii) of the GST Act). Therefore, if there is more than one recipient of the taxable supply, both recipients' identities or ABNs must appear.
In this case, the identities of both recipients appear on the invoice. Therefore, the rest of the requirements of a tax invoice are satisfied, and the entity is issuing a tax invoice that meets the requirements under subsection 29-70(1) of the GST Act. Note : it is the responsibility of each recipient to determine, based on their own individual usage of the item, whether the supply constitutes a creditable acquisition under section 11-5 of the GST Act. If the supply does constitute a creditable acquisition under section 11-5 of the GST Act, each recipient also has the responsibility for calculating the amount of any input tax credit that they may be entitled to (Division 11 of the GST Act).