{"id":"F2026L00194","name":"A New Tax System (Goods and Services Tax) (Attribution Rules – Supplies of Electricity Distribution Services) Determination 2026","slug":"a-new-tax-system-goods-and-services-tax-attribution-rules-supplies-of-electricity-distribution-servi","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":443168,"registerId":"F2026L00194-fast-fetch-1775958074510","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 – Supplies of Electricity Distribution Services) Determination 2026","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\ntitle: ATO Legislative Instrument Template\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 – Supplies of Electricity Distribution Services) Determination 2026\n\nI, Will Day, Deputy Commissioner of Taxation, make the following determination.\n\nDated  25 February 2026\n\nWill Day\n\nDeputy Commissioner of Taxation\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 supplies of electricity distribution services\n\n7  Adjustment attribution rules for supplies of electricity distribution services\n\nSchedule 1—Repeals\n\nGoods and Services Tax:  Particular Attribution Rules Determination (No. 29) 2016 for Electricity Distribution Services\n\n \n\n \n\n1  Name\n\n  This instrument is the A New Tax System (Goods and Services Tax) (Attribution Rules – Supplies of Electricity Distribution Services) 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The day after this instrument is registered.\n\n\nNote: This table relates only to the provisions of this instrument as originally made.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\n1.       adjustment;\n2.      associate;\n3.       consideration;\n4.      entity;\n5.       invoice;\n6.       taxable supply;\n7.      tax period.\n\n\n  In this instrument:\n\nAct means the A New Tax System (Goods and Services Tax) Act 1999.\n\nbilling agent means an entity that is authorised to issue invoices on behalf of a supplier of electricity distribution services but is not an associate of that supplier.\n\nelectricity distribution services means the delivery of electricity to end-use customers, along with the provision of related support services.\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 supplies of electricity distribution services\n\n  The GST payable by a supplier of a taxable supply of electricity distribution services is attributable to the tax period in which the supplier receives from the billing agent all the information necessary to ascertain the total consideration for the supply, in circumstances where:\n\n (a) the supplier does not account on a cash basis; and\n\n (b) the billing agent issues an invoice for the supply; and\n\n (c) the supplier is unable to ascertain the total consideration for the supply in an earlier tax period, if in that earlier tax period:\n\n (i) any consideration is received for the supply; or\n\n (ii) the billing agent issues an invoice relating to the supply.\n\n7  Adjustment attribution rules for supplies of electricity distribution services\n\n  An adjustment relating to a taxable supply of electricity distribution services is attributable to the tax period in which the supplier receives from the billing agent all the information necessary to ascertain the amount of the adjustment, in circumstances where the supplier is unable to ascertain the amount of the adjustment without that information.\n\n\n\n\nSchedule 1—Repeals\n\nGoods and Services Tax:  Particular Attribution Rules Determination (No. 29) 2016 for Electricity Distribution Services\n\n1  The whole of the instrument\n\nRepeal the instrument\n","sortOrder":0}],"analysis":{"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"This is a straightforward remake of an existing 2016 determination with the same scope. It maintains the original purpose of providing specific attribution rules for electricity distribution services using billing agents. No expansion of scope is evident."},"complexity_factors":["Short document (approximately 2 pages of substantive content)","Only 2 defined terms in the instrument itself ('Act' and 'billing agent'), though references 7 defined terms from the parent Act","Simple conditional structure: two main operative sections (sections 6 and 7) with straightforward 'if-then' logic","Single cross-reference to parent legislation (subsection 29-25(1) of the GST Act)","No nested exceptions or complex definitional chains","Clear repeal and replacement structure (Schedule 1)"],"plain_english_summary":"This ATO determination lets electricity distribution businesses delay attributing GST on distribution services until they receive complete billing information from third‑party billing agents, rather than when an invoice is issued or payment received. It affects distributors and their unrelated billing agents and prevents premature GST outlays and cash‑flow strain by aligning tax timing with when precise liability can be calculated. It replaces the 2016 Determination No. 29."},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":true,"description":"This instrument repeals the earlier Particular Attribution Rules Determination (No. 29) 2016 and replaces it with rules that attribute GST and related adjustments to the tax period when the supplier receives from the billing agent all information necessary to determine total consideration or the adjustment (s6, s7; Schedule 1). That repeal plus the new reliance on billing‑agent information narrows attribution to an event tied to information flow and alters timing outcomes for non-cash‑basis suppliers, requiring them and billing agents to modify billing and records processes."},"complexity_factors":["Technical interaction with the A New Tax System (Goods and Services Tax) Act 1999 definitions (instrument relies on Act definitions) (s4 note).","Conditional rule limited to suppliers who do not account on a cash basis (s6(a)) — creates a bifurcated treatment depending on accounting method.","Attribution depends on receipt of 'all the information necessary' from a billing agent, a fact‑specific threshold that may require judgement and generate disputes (s6, s7).","Multiple triggering events are referenced (receipt of consideration, billing agent invoice) which require tracking across tax periods (s6(c)(i)-(ii)).","Mirror adjustment rules for post-supply changes increase recordkeeping and monitoring obligations (s7).","Repeal of the 2016 particular attribution determination means operational change and a need to transition compliance processes (Schedule 1).","Commencement timing (the day after registration) creates an immediate compliance deadline for affected entities (s2)."],"plain_english_summary":"**What it does:** This determination fixes when GST is attributable for taxable supplies of electricity distribution services: for suppliers who do not account on a cash basis, GST is attributable in the tax period when the supplier receives from the billing agent all information needed to ascertain total consideration (s6). It also makes adjustments attributable when that information is received (s7).\n\nIt affects electricity distribution suppliers and billing agents by changing the timing of tax liabilities and adjustment reporting, with direct implications for cash flow and compliance."}},"importantCases":[],"_links":{"self":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-supplies-of-electricity-distribution-servi","history":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-supplies-of-electricity-distribution-servi/history","analysis":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-supplies-of-electricity-distribution-servi/analysis","conflicts":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-supplies-of-electricity-distribution-servi/conflicts","importantCases":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-supplies-of-electricity-distribution-servi/important-cases","documents":"/api/acts/a-new-tax-system-goods-and-services-tax-attribution-rules-supplies-of-electricity-distribution-servi/documents"}}