1 Is the trustee for the superannuation fund (Fund) an entity pursuant to section 184-1 of the A New Tax System Goods and Services Tax Act 1999 (GST Act)?
Yes Question 2 Does the Fund make an input taxed financial supply to Clients pursuant to section 40-5 of the GST Act? Answer Yes Question 3 Is the Adviser Services Fee (ASF) consideration for supplies by an Adviser to the Fund for the purposes of section 11-5 of the GST Act? Answer No, the ASF is not consideration for supplies by an Adviser to the Fund for the purposes of section 11-5 of the GST Act. Question 4 Are the supplies by Advisers, for which the ASF are paid as consideration, reduced credit acquisitions (RCA) under paragraphs (a), (b) or (e) of Item 23 and/or paragraphs (a)-(g) or (i) of Item 24 of section 70-5.02 of the GST Regulations such that the Fund is entitled to a reduced input tax credit (RITC) at the rate of 75%? Answer No, as the ASF is not consideration for a supply by the Adviser made to the Fund, a RCA is not made and there is no entitlement to any RITC. This ruling applies for the following period : 1 July 2024 till quarter ending 30 June 2029 The scheme commenced on: 1 July 2024
The Fund is a superannuation fund as defined in the Income Tax Assessment Act 1997 . The Fund has provided a number of documents which set out the framework that applies between an Adviser, the Fund, and Clients which define this arrangement.
A New Tax System (Goods and Services Tax) Act 1999 section 9-5 A New Tax System (Goods and Services Tax) Act 1999 section 11-5 A New Tax System (Goods and Services Tax) Act 1999 section 40-5 A New Tax System (Goods and Services Tax) Act 1999 section 70-5 A New Tax System (Goods and Services Tax) Act 1999 section 70-10 A New Tax System (Goods and Services Tax) Act 1999 section 184-1 A New Tax System (Goods and Services Tax) Regulations 2019 subsection 40-5.09(3) A New Tax System (Goods and Services Tax) Regulations 2019 section 70-5.02 A New Tax System (Goods and Services Tax) Regulations 2019 subsection 70-5.02(2) item 32