{"id":"F2026L00189","name":"A New Tax System (Goods and Services Tax) (Attribution Rules – Prepayment for a Telecommunication Supply) Determination 2026","slug":"a-new-tax-system-goods-and-services-tax-attribution-rules-prepayment-for-a-telecommunication-supply-","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":443165,"registerId":"F2026L00189-fast-fetch-1775958072628","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"A New Tax System (Goods and Services Tax) (Attribution Rules – Prepayment for a Telecommunication Supply) Determination 2026","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\n---\n\n![Commonwealth Coat of Arms of Australia](image.001.jpeg)\n\n \n\nA New Tax System (Goods and Services Tax) (Attribution Rules – Prepayment for a Telecommunication Supply) Determination 2026\n\nI, Will Day, Deputy of Commissioner of Taxation, make the following determination.\n\nDated 25 February 2026\n\nWill Day\n\nDeputy Commissioner of Taxation\n\n \n\n \n\n \n\nContents\n\n1  Name\n\n2  Commencement\n\n3  Authority\n\n4  Definitions\n\n5  Schedules\n\n6  GST attribution rules for a prepayment for a telecommunication supply\n\nSchedule 1—Repeals\n\nGoods and Services Tax: Particular Attribution Rules Determination (No. 28) 2016 for Prepayments of Telephone Services\n\n \n\n \n\n1  Name\n\n  This instrument is the A New Tax System (Goods and Services Tax) (Attribution Rules – Prepayment for a Telecommunication Supply) Determination 2026.\n\n2  Commencement\n\n (1) Each provision of this instrument specified in column 1 of the table commences, or is taken to have commenced, in accordance with column 2 of the table. Any other statement in column 2 has effect according to its terms.\n\n \n\n- Commencement information\n- Column 1 Column 2 Column 3\n- Provisions Commencement Date/Details\n- 1. The whole of this instrument The day after this instrument is registered.\n\n\nNote: This table relates only to the provisions of this instrument as originally made. It will not be amended to deal with any later amendments of this instrument.\n\n (2) Any information in column 3 of the table is not part of this instrument. Information may be inserted in this column, or information in it may be edited, in any published version of this instrument.\n\n3  Authority\n\n  This instrument is made under subsection 29-25(1) of the Act.\n\n4  Definitions\n\nNote: A number of expressions used in this instrument are defined in section 195-1 of the Act, including the following:\n\n(a) consideration;\n\n(b) invoice;\n\n(c) taxable supply;\n\n(d) tax period;\n\n(e) telecommunication supply.\n\n  In this instrument:\n\nAct means the A New Tax System (Goods and Services Tax) Act 1999.\n\nprepayment means a payment made by a customer to a telecommunications provider for a taxable supply that is a telecommunication supply before the provider has issued an invoice for the supply as part of its regular billing cycle.\n\ntelecommunications provider means an entity that makes telecommunication supplies to the public for a fee.\n\n5  Schedules\n\n  Each instrument that is specified in a Schedule to this instrument is amended or repealed as set out in the applicable items in the Schedule concerned, and any other item in a Schedule to this instrument has effect according to its terms.\n\n6  GST attribution rules for a prepayment for a telecommunication supply\n\n  If a prepayment for a taxable supply that is a telecommunication supply is made to a telecommunications provider that does not account on a cash basis, the GST payable by the provider on the supply is attributable to the earlier of:\n\n (a) the tax period in which an invoice is issued in relation to the supply; and\n\n (b) the tax period in which an invoice would have been issued by the telecommunications provider in relation to the supply had the prepayment not been made.\n\n\n\n\nSchedule 1—Repeals\n\nGoods and Services Tax: Particular Attribution Rules Determination (No. 28) 2016 for Prepayments of Telephone Services\n\n1  The whole of the instrument\n\nRepeal the instrument\n","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":2,"scope_assessment":{"changed":false,"description":"The legislation maintains its original narrow scope. It replaces the 2016 Determination (No. 28) with substantively identical rules for GST attribution of telecom prepayments. The scope remains tightly focused on the specific timing issue for non-cash-basis telecom providers and has not expanded beyond this original purpose."},"complexity_factors":["Very short instrument (approximately 1.5 pages of substantive content)","Only 2 defined terms in the instrument itself ('prepayment' and 'telecommunications provider'), with 5 additional terms referenced from the parent Act","Single operative provision (section 6) with straightforward conditional logic","No nested exceptions or complex cross-referencing beyond the standard reference to the enabling Act","Simple binary structure: definitions + single rule + repeal schedule","Clear temporal test ('earlier of') with only two alternatives"],"plain_english_summary":"This is a tax rule about when phone and internet companies must pay GST on money they receive before sending a bill.\n\n**What it does:**\nNormally, businesses pay GST in the tax period when they issue an invoice or receive payment (whichever comes first). But telecom companies often receive **prepayments** — money paid upfront by customers before any bill is issued. This rule fixes a timing problem: without it, the company might have to pay GST immediately upon receiving the prepayment, even though they haven't issued an invoice yet.\n\n**The fix:**\nFor telecom companies that **don't** use cash accounting (meaning they account for GST when invoices are issued, not when cash is received), GST on prepayments is now due in the earlier of:\n* The tax period when they actually issue the invoice; or\n* The tax period when they **would have** issued the invoice if the customer hadn't prepaid.\n\n**Who it affects:**\n* **Telecommunications providers** (phone, internet, mobile companies) that receive upfront payments from customers\n* **Customers** — indirectly, as this affects how providers manage their tax cash flow\n\n**Why it matters:**\nThis prevents telecom companies from being forced to pay GST on money received before their normal billing cycle kicks in. It aligns the tax timing with their actual business practices. The rule also **replaces** an older 2016 rule that did the same thing, updating the framework without changing the underlying policy."},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"}},"importantCases":[],"_links":{"self":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-prepayment-for-a-telecommunication-supply-","history":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-prepayment-for-a-telecommunication-supply-/history","analysis":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-prepayment-for-a-telecommunication-supply-/analysis","conflicts":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-prepayment-for-a-telecommunication-supply-/conflicts","importantCases":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-prepayment-for-a-telecommunication-supply-/important-cases","documents":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-prepayment-for-a-telecommunication-supply-/documents"}}