{"id":"F2017L00366","name":"Goods and Services Tax: Application of Particular Attribution Rules Determinations (Determination) 2017","slug":"goods-and-services-tax-application-of-particular-attribution-rules-determinations-determination-2017","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":96089,"registerId":"commonwealth-F2017L00366-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Goods and Services Tax: Application of Particular Attribution Rules Determinations (Determination) 2017","content":"Legislative Instrument\n\nGoods and Services Tax: Application of Particular Attribution Rules Determinations (Determination) 2017\n\nI, Timothy Dyce, Deputy Commissioner of Taxation, make this determination under subsection 29-25(1) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act).\n\nTimothy Dyce\n\nDeputy Commissioner of Taxation\n\nDated: 28/03/2017\n\n1.  Name of determination\n\nThis determination is the Goods and Services Tax: Application of Particular Attribution Rules Determinations (Determination) 2017.\n\n2. Commencement\n\nThis determination commences on the day after its registration on the Federal Register of Legislation.\n\n3. Repeal of previous determination\n\nThis determination repeals and replaces determination A New Tax System (Goods and Services Tax) Act 1999 (Application of Particular Attribution Rules Determinations) Determination (No. 1) 2000 (F2006B11604), registered on 20 November 2006.\n\n4. Application\n\nThis determination applies where two or more determinations specify different attribution rules for the same kind of taxable supply or creditable acquisition.\n\nThe determination is substantially the same as the previous determination that it replaces. An entity that satisfied the requirements of the previous determination and that is an entity for which two or more determinations specify different attribution rules for the same kind of taxable supply or creditable acquisition will satisfy the requirements of the determination.\n\n5. Attribution of GST payable on a taxable supply of a kind described in more than one determination made under section 29-25\n\nThe GST payable is attributable to the latter, or latest, of the tax periods where:\n\n    (1) you make a taxable supply to which more than one determination made by the Commissioner under subsection 29-25(1) of the GST Act applies; and\n\n    (2) the attribution rules set out in the determinations result in the GST payable on the taxable supply being attributable to different tax periods.\n\n6. Attribution of an input tax credit arising from a creditable acquisition of a kind described in more than one determination made under section 29‑25\n\nThe input tax credit is attributable to the latter, or latest, of the tax periods where:\n\n    (1) you make a creditable acquisition to which more than one determination made by the Commissioner under subsection 29-25(1) of the GST Act applies; and\n\n    (2) the attribution rules set out in the determinations result in the input tax credit for the creditable acquisition being attributable to different tax periods.\n\n7. Definitions\n\nExpressions in this determination have the same meaning as in the GST Act.","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 direct replacement of a 2006 determination with substantially identical content. The document explicitly states it is 'substantially the same as the previous determination' and serves the same narrow purpose of resolving conflicts between attribution rules. No expansion of scope."},"complexity_factors":["Very short document (7 sections, ~400 words)","Only 1 defined term reference (expressions take meaning from parent Act)","No nested exceptions or conditional logic beyond simple 'if A and B, then C' structure","Single cross-reference to parent GST Act (section 29-25)","Straightforward operative mechanism (later date prevails) with no sub-conditions"],"plain_english_summary":"When two ATO determinations tell you to report the same GST transaction in different tax periods, this rule resolves the conflict by using the later date. It applies to GST-registered businesses making taxable supplies or creditable acquisitions and only affects which period you report in. It does not change GST amounts—just timing—to reduce misreporting, penalties and cash‑flow uncertainty."},"flash_summary":{"complexity_score":2,"scope_assessment":{"changed":false,"description":"The instrument expressly repeals and replaces the 2000 determination but states it is substantially the same (see ss3–4). Its operational scope — resolving attribution when multiple Commissioner determinations apply to the same kind of taxable supply or creditable acquisition — is unchanged."},"complexity_factors":["Narrow, single-rule outcome (conflict resolved by choosing the later tax period) reduces legal complexity (see s5 and s6).","Requires taxpayers to identify when multiple Commissioner determinations apply to the same supply or acquisition, creating modest compliance and record‑keeping burden (see Application and s5–s6).","Interaction with the GST Act terminology and tax period definitions may require statutory interpretation to determine which period is 'later' in complex cases (references: instrument preamble and s7).","Repeals and replaces an earlier determination but expressly remains 'substantially the same', limiting substantive change and transitional complexity (see ss3–4).","Decision-making power rests with the Commissioner (instrument made under subsection 29-25(1)), so taxpayers must track Commissioner determinations to apply the rule."],"plain_english_summary":"This determination resolves what tax period counts for GST obligations when two or more Commissioner determinations give different attribution rules. If multiple determinations apply to the same supply or acquisition, the GST payable or the input tax credit is attributed to the later (latest) of the tax periods.\n\nIt affects entities that make taxable supplies or creditable acquisitions covered by more than one such determination, because it changes the timing of when GST must be reported and credits claimed, affecting cash flow and compliance."}},"importantCases":[],"_links":{"self":"/api/acts/goods-and-services-tax-application-of-particular-attribution-rules-determinations-determination-2017","history":"/api/acts/goods-and-services-tax-application-of-particular-attribution-rules-determinations-determination-2017/history","analysis":"/api/acts/goods-and-services-tax-application-of-particular-attribution-rules-determinations-determination-2017/analysis","conflicts":"/api/acts/goods-and-services-tax-application-of-particular-attribution-rules-determinations-determination-2017/conflicts","importantCases":"/api/acts/goods-and-services-tax-application-of-particular-attribution-rules-determinations-determination-2017/important-cases","documents":"/api/acts/goods-and-services-tax-application-of-particular-attribution-rules-determinations-determination-2017/documents"}}