{"id":"F2025L00517","name":"Taxation Administration (Reporting Exemptions for Electronic Distribution Platform Operators) Determination 2025","slug":"f2025l00517","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":442823,"registerId":"F2025L00517-fast-fetch-1775957750117","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Taxation Administration (Reporting Exemptions for Electronic Distribution Platform Operators) Determination 2025","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\n---\n\n?xml version=\"1.0\" encoding=\"utf-8\" standalone=\"no\"?>\n\n![Commonwealth Coat of Arms of Australia](image.001.jpeg)\n\n \n\nTaxation Administration (Reporting Exemptions for Electronic Distribution Platform Operators) Determination 2025\n\nI, Ben Kelly, Deputy Commissioner of Taxation, make the following determination.\n\nDated 6 March 2025\n\nBen Kelly\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  Exemption for certain operators of electronic distribution platforms\n\n7  Exemption for transactions involving certain types of suppliers\n\n8  Exemption for transactions involving certain types of supplies\n\nSchedule 1—Repeals\n\nTaxation Administration (Reporting Exemptions for Electronic Distribution Platform Operators) Determination 2024\n\n \n\n \n\n1  Name\n\n  This instrument is the Taxation Administration (Reporting Exemptions for Electronic Distribution Platform Operators) Determination 2025.\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of this instrument 1 July 2025. 1 July 2025.\n\n\nNote: This table relates only to the provisions of this instrument as originally made.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 396-70(4) in Schedule 1 to the Act.\n\n4  Definitions\n\n  In this instrument:\n\nAct means the Taxation Administration Act 1953.\n\nassets available for booking includes any assets that have already been booked for a day, or are temporarily unavailable for booking.\n\nNote: An asset may be temporarily unavailable, for example, because it is undergoing maintenance.\n\ncharter service means a passenger travel service, where a customer:\n\n (a) hires an entire aircraft, motor vehicle or vessel; and\n\n (b) can specify or negotiate some or all of the terms and conditions attached to, or the nature of, the service to be provided.\n\nelectronic distribution platform has the same meaning as in section 84-70 of the GST Act, but disregarding paragraph 84-70(1)(c) of the GST Act.\n\nGST Act means the A New Tax System (Goods and Services Tax Act) 1999.\n\nindirect tax zone has the same meaning as in the GST Act, but as if that definition included the external Territories.\n\nlisted entity means an entity whose membership interests are publicly traded on an approved stock exchange within the meaning of section 995-1 of the Income Tax Assessment Act 1997.\n\npermanent attraction or experience means an attraction or experience (other than a scheduled event) that is open to the public on a regular and ongoing basis, for which:\n\n (a) the opening times, price, and terms and conditions are set by the supplier; and\n\n (b) any member of the public may make a booking.\n\nprorated amount means:\n\n (a) in relation to substantial property, the amount worked out using the following formula:\n\n (i) step 1: divide the number of days the supplier had the property listed on the electronic distribution platform in the 12 month period ending on the last day of the reporting period by 365; and\n\n (ii) step 2: multiply the result of step 1 by 2,000;\n\n (b) in relation to a substantial supplier, the amount worked out using the following formula:\n\n (i) step 1: divide the number of days the supplier had supplies available to be made through the electronic distribution platform in the 12 month period ending on the last day of the reporting period by 365; and\n\n (ii) step 2: multiply the result of step 1 by $1,000,000.\n\nreportable transaction means a transaction described in column 2 of table item 15 in section 396-55 in Schedule 1 to the Act.\n\nreporting period means the period set out in paragraph 396-55(a) in Schedule 1 to the Act.\n\nscheduled event means a one-off event, or series of events scheduled in a particular location for a temporary period, for which:\n\n (a) the time, price, and terms and conditions are set by the supplier; and\n\n (b) any member of the public may make a booking.\n\nscheduled passenger travel service means a passenger travel service, including an arranged tour:\n\n (a) supplied as a scheduled service on a pre-defined route operated by the supplier, for a price and with terms and conditions set by the supplier; and\n\n (b) on which any member of the public may make a booking.\n\nsubstantial property means real property where, in relation to a reporting period and an electronic distribution platform, at least the following number of transactions (whether involving the grant of a lease or license or otherwise) were facilitated by the electronic distribution platform for that property:\n\n (a) 2000 transactions in the 12 months ending on the last day of the reporting period, where the property was listed on the platform for that entire period; or\n\n (b) the prorated amount of transactions, where the property was first listed on the platform in the 12 months ending on the last day of the reporting period.\n\nsubstantial supplier means a supplier that, in relation to a reporting period and an electronic distribution platform, made a total value of supplies facilitated by the electronic distribution platform of at least:\n\n (a) $1,000,000 (including GST) in the 12 months ending on the last day of the reporting period; or\n\n (b) the prorated amount, where the supplier started to use the platform in the 12 months ending on the last day of the reporting period.\n\ntaxi travel has the same meaning as in the GST Act.\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  Exemption for certain operators of electronic distribution platforms\n\n  The operator of an electronic distribution platform (the first platform) is not required to prepare and give a report about a reportable transaction if:\n\n (a) the supply was made through the first platform and at least one other electronic distribution platform interposed between the first platform and the supplier;\n\n (b) the operator of the first platform did not itself provide any consideration for the supply directly to the supplier;\n\n (c) the operator of another electronic distribution platform provided all or part of the consideration for the supply to the supplier and has a reporting obligation under table item 15 in section 396-55 in Schedule 1 to the Act in relation to the reportable transaction; and\n\n (d) the operator of the first platform has notified the Commissioner in writing that they would be applying this exemption on or before the later of:\n\n (i) the day they would otherwise be required to give a report under paragraph 396-55(b) in Schedule 1 to the Act; or\n\n (ii) where the operator asks the Commissioner for an extension of time and the Commissioner agrees, a day notified by the Commissioner in writing.\n\n7  Exemption for transactions involving certain types of suppliers\n\n (1) The operator of an electronic distribution platform is not required to prepare and give a report about a reportable transaction if the supplier was:\n\n (a) a listed entity, or wholly-owned subsidiary of a listed entity; or\n\n (b) a government department, agency, or authority (however described and at any level of government), or an entity wholly-owned by a government.\n\n (2) The operator of an electronic distribution platform is not required to prepare and give a report about a reportable transaction if the supplier was a substantial supplier.\n\n (3) The operator of an electronic distribution platform is not required to prepare and give a report about a reportable transaction in relation to a supply made through the electronic distribution platform if the operator is treated as being the supplier under section 84-55 of the GST Act, but disregarding section 84-60 of the GST Act.\n\n8  Exemption for transactions involving certain types of supplies\n\n  The operator of an electronic distribution platform is not required to prepare and give a report about a reportable transaction if:\n\n (a) the transaction involved the provision of consideration relating to a substantial property;\n\n (b) the following conditions are met:\n\n (i) the supplier has provided the operator with one or more addresses, and none of those addresses are within the indirect tax zone;\n\n (ii) the supply was of a service that was not provided within the indirect tax zone;\n\n (iii) the consideration provided to the supplier was not paid to an account held with a financial institution in the indirect tax zone; and\n\n (iv) there is no other information available to the operator that indicates that the supplier resides in the indirect tax zone;\n\n (c) the transaction was a mere booking or reservation for a supply to be made in the future, where:\n\n (i) the consideration for the supply was not specified at the time the booking or reservation was made;\n\n (ii) the consideration for the supply will not be provided via the platform; and\n\n (iii) the operator of the platform will not have visibility of whether the supply is made in practice, or whether consideration is provided for the supply;\n\n (d) the transaction involved the supply of a scheduled passenger travel service other than a charter service or taxi travel, where the supplier had made at least 10 places for that service available for booking on the platform;\n\n (e) the transaction involved the supply of a right to attend or participate in a scheduled event, where the supplier had made at least 200 places for that event available for booking on the platform;\n\n (f) the transaction involved the supply of a right to attend or participate in a permanent attraction or experience, where the supplier had made at least 50 places for that attraction or experience available for booking on the platform each day it was open during the reporting period; or\n\n (g) the transaction involved the supply of an asset by way of rent or lease, other than real property, where:\n\n (i) the transaction was not for the supply of a specific asset; and\n\n (ii) the supplier had at least 50 assets available for booking on the platform each day during the reporting period.\n\n\n\n\nSchedule 1—Repeals\n\nTaxation Administration (Reporting Exemptions for Electronic Distribution Platform Operators) Determination 2024\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":6,"scope_assessment":{"changed":false,"description":"This Determination appears to maintain the same scope as its predecessor (the 2024 Determination which it repeals). It continues to provide targeted exemptions from reporting obligations for electronic distribution platform operators. While the specific thresholds and definitions may have been refined, the fundamental purpose—carving out exceptions to reduce compliance burden for specific categories of suppliers, properties, and transaction types—remains consistent with the original intent of the reporting framework established under the Taxation Administration Act."},"complexity_factors":["14 defined terms in section 4, many cross-referencing other Acts (GST Act, Income Tax Assessment Act 1997, Taxation Administration Act 1953)","Nested conditional logic in section 6 requiring four cumulative conditions (a)-(d) for the multi-platform exemption","Mathematical formulas for 'prorated amounts' involving multi-step calculations with 365-day periods and thresholds","Multiple cross-references to external legislation (section 396-55, 396-70, 84-55, 84-60 of various Acts)","Complex threshold tests for 'substantial supplier' ($1M/12 months or pro-rata) and 'substantial property' (2,000 transactions/12 months or pro-rata)","Seven distinct exemption categories in section 8, each with specific sub-conditions (e.g., 8(b) has four separate geographical tests)","Exception to exception structure: section 8(d) exempts scheduled passenger travel but explicitly excludes charter services and taxi travel","Temporal calculations requiring 12-month lookback periods ending on reporting period dates"],"plain_english_summary":"This Determination narrows when electronic distribution platform operators (e.g., booking sites, ride‑share or accommodation platforms) must report transaction details to the ATO by creating targeted exemptions. It covers situations like multi‑platform reporting, transactions involving large or government entities, certain high‑volume suppliers or supply types, and where the platform is already treated as the GST supplier.\n\nBy removing duplicate or low‑risk reporting obligations, it reduces compliance burden for platforms and affected suppliers and updates the framework for the 2025–26 year."},"flash_summary":{"complexity_score":7,"scope_assessment":{"changed":true,"description":"This instrument repeals the 2024 Determination (Schedule 1) and replaces it with a new set of exemptions (ss6–8), effective 1 July 2025 (s2). Mechanically, it reduces the reporting universe for platform operators in specified situations—transfers reporting to another platform when that platform provides consideration (s6), exempts transactions involving listed entities, governments or 'substantial suppliers' (s7), and exempts specified supply types and circumstances (s8). The changes shift compliance and verification burdens onto platform operators (see ss6–8) and leave some timing discretion to the Commissioner for notification extensions (s6(d)(ii))."},"complexity_factors":["Cross-references to other tax laws and definitions (Taxation Administration Act, GST Act, Income Tax Assessment Act) increase interpretive complexity (see s3 and s4 definitions).","Detailed numeric thresholds and counting rules for exemptions (e.g. 2000 transactions, $1,000,000 value, 200/50/10 place counts) require data aggregation and monitoring (see s4 definitions; s8(d)-(g)).","Prorated amount formulas for 'substantial property' and 'substantial supplier' impose record-keeping and calculation requirements across 12‑month periods (see s4: 'prorated amount').","Multi-platform exemption depends on establishing which platform paid suppliers and requires written notification to the Commissioner and possible extension handling—creates timing and procedural compliance obligations (see s6(a)-(d)).","Operators must determine supplier status (listed entity, government, substantial supplier) and whether they are treated as supplier under the GST Act, implicating cross‑statute analysis (see s7(1)–(3); s4 'listed entity'; reference to section 84-55 GST Act).","Offshore/residency conditions require verification of supplier addresses, payment account locations and absence of other indicators—adds evidentiary burdens (see s8(b)(i)-(iv)).","Definitions like 'assets available for booking' and 'each day during the reporting period' create operational measurement challenges for platforms with changing inventories (see s4 definitions; s8(g)).","The instrument repeals the 2024 Determination, so operators must reconcile the new exemptions against prior practice (Schedule 1).","Commissioner discretion to grant extensions for notification timing introduces case-by-case uncertainty (see s6(d)(ii))."],"plain_english_summary":"This Determination narrows reporting obligations for operators of electronic distribution platforms by creating specific exemptions for certain transactions, suppliers and supply types, effective 1 July 2025. It affects platform operators who otherwise must prepare and give reports about sales they facilitate; in defined cases the reporting duty shifts to another platform or is removed (for example where another platform pays the supplier, where the supplier is a listed entity or government, or where supplies meet enumerated thresholds/conditions)."}},"importantCases":[],"_links":{"self":"/api/acts/f2025l00517","history":"/api/acts/f2025l00517/history","analysis":"/api/acts/f2025l00517/analysis","conflicts":"/api/acts/f2025l00517/conflicts","importantCases":"/api/acts/f2025l00517/important-cases","documents":"/api/acts/f2025l00517/documents"}}