Claims for GST refunds beyond four years arising from the reclassification of a previously taxable supply as GST free.

A taxpayer has paid GST on a supply that they considered at the time was a taxable supply but they now contend that the supply is in fact not a taxable supply. 2. The taxpayer at the time of making the supply issued tax invoices to the recipient who was registered for GST or required to be registered. 3. The taxpayer's notification is now seeking a refund of the GST purportedly overpaid in an earlier tax period where more than four years has elapsed since the end of that tax period. 4. Depending on whether or not the taxpayer reimburses the refund of the overpaid GST to the registered entity who was the recipient of the supply, there may be an unintended windfall gain to either the taxpayer who made the supply or to the recipient of the supply. 5. In some cases there are arrangements in place for the supplier and recipient of the supply to share a percentage of the refund sought from the Commissioner.