1 Are you making a taxable supply under section 9-5 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) when you receive a payment from a remittance provider?
1 Where the payment received relates to money that is transferred overseas or being transferred between entities located overseas, you are making a GST-free supply under table item 4 of subsection 38-190(1) of the GST Act. Where the payment received relates to money that is transferred from overseas into Australia or within Australia, the supply is a taxable supply. Question 2 Are you a financial supply facilitator for the purposes of section 40-5.07 of the A New Tax System (Goods and Services Tax) Regulations 2019 when you provide services to a remittance provider? Answer 2 No. This ruling applies for the following period : 1 July 2025 to 30 June 2029 The scheme commenced on: 8 September 2025
You and Entity A entered into a "Referring Party / Introducing Broker Agreement" (IB Agreement). You provide a service of referring a prospective client to Entity A. Entity A provides remittance services which includes funds transferred from an: • Australian entity to an overseas entity. • Australian entity to another Australian entity. • overseas entity to an Australian entity. • overseas entity to another overseas entity. When a client wants to remit money: • You collect and compile the client's information and documents. • You forward the client's information to Entity A, who will undertake the 'Know Your Customer', 'Anti Money-Laundering' and 'Counter Terrorism Finance' checks. Entity A decides whether to accept the client as a customer. • Entity A gives you the "interactive brokers rate" for the foreign currency transaction. • You determine a markup for the transaction and quote the client the "customer rate".
• If the client decides to proceed with the transaction, they send funds directly to Entity A's nominated bank account or a client-specific virtual account established by/for Entity A. • Once cleared funds are received, Entity A executes the foreign currency remittance and directs funds to the client's nominated beneficiary's account. • After completion, Entity A confirms the margin (the difference between the customer rate and the interactive brokers rate) and pays you a commission in accordance with the IB Agreement.
A New Tax System (Goods and Services Tax) Act 1999 section 9-5 A New Tax System (Goods and Services Tax) Act 1999 subsection 38-190(1) A New Tax System (Goods and Services Tax) Regulations 2019 section 40-5.07 A New Tax System (Goods and Services Tax) Regulations 2019 section 40-5.09 Question 1 Detailed reasoning Generally, an entity makes a taxable supply under section 9-5 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act) where the entity: • makes a supply for consideration (payment); and • the supply is made in the course or furtherance of an enterprise; and • the supply is connected with the indirect tax zone (Australia); and • the entity is registered or required to be registered for GST; and •