{"id":"F2019L00609","name":"Goods and Services Tax: Digital Currency Conversion Determination 2019","slug":"goods-and-services-tax-digital-currency-conversion-determination-2019","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":99224,"registerId":"commonwealth-F2019L00609-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"Name of determination","sectionType":"part","heading":"Name of determination","content":"## Name of determination\n\n    This determination is the Goods and Services Tax: Digital Currency Conversion Determination 2019.","sortOrder":0},{"sectionNumber":"Commencement","sectionType":"part","heading":"Commencement","content":"## Commencement\n\n    2. This determination applies on the day after it is registered.","sortOrder":1},{"sectionNumber":"Application","sectionType":"part","heading":"Application","content":"## Application\n\n    3. This determination applies to an entity that in working out the value of a taxable supply that has any amount of consideration for the supply expressed in digital currency. That amount must be converted into Australian currency using the method in section 4.","sortOrder":2},{"sectionNumber":"Manner in which an amount of considerati","sectionType":"part","heading":"Manner in which an amount of consideration for the supply is worked out","content":"## Manner in which an amount of consideration for the supply is worked out\n\n    4. You must convert the amount of consideration expressed in digital currency using the following formula:\n\nAmount of digital currency x your particular exchange rate on the conversion day\n\nYou must use your particular exchange rate consistently.\n\nOther than an agreed rate, your particular exchange rate must reflect the GST inclusive market value of the digital currency in Australian currency.","sortOrder":3},{"sectionNumber":"Definitions","sectionType":"part","heading":"Definitions","content":"## Definitions\n\n    5. The following expressions are defined for the purposes of this determination:\n\nagreed rate means a particular exchange rate agreed to between a supplier and a registered recipient. The agreed rate only applies for supplies made under the agreement and for the period of the agreement. Where the supplier and the recipient are associates the agreed rate must reflect the rate agreed to by parties dealing at arm's length.\n\nconversion day is the date you use to convert digital currency into Australian currency under this determination:\n\n(a) when you account for GST on a basis other than cash your conversion day is the earlier of:\n\n(i) the day on which any of the consideration is received for the supply (the receipt date); or\n\n(ii) the transaction date or the invoice date (whichever you have chosen).\n\n(b) when you account for GST on a cash basis, your conversion day is:\n\n(i) the transaction date; or\n\n(ii) the invoice date; or\n\n(iii) the day on which any of the consideration is received for the supply.\n\n(c) if you are a non-resident that is not a limited registration entity, and you are making inbound intangible consumer supplies, offshore supplies of low value goods, or both, your conversion day is:\n\n(i) a day specified in either paragraphs (a) or (b) of this definition for any types of supplies that you make (including inbound intangible consumer supplies or offshore supplies of low value goods); or\n\n(ii) for all of your inbound intangible consumer supplies, all of your offshore supplies of low value goods, or both:\n\n    the final day of the relevant tax period in which GST is payable (in which case, the conversion day for your other types of supplies is the day specified in either paragraphs (a) or (b) of this definition); or\n    the earlier of the day on which you lodge your activity statement for a tax period or the due date for lodgement of that activity statement (in which case, the conversion day for your other types of supplies is the day specified in either paragraphs (a) or (b) of this definition).\n\n(d) if you are a non-resident that is a limited registration entity, your conversion day for all of your supplies is:\n\n(i) a day specified in either paragraphs (a) or (b) of this definition; or\n\n(ii) the final day of the relevant tax period in which GST is payable on your supplies; or\n\n(iii) the earlier of the day on which you lodge your activity statement for a tax period or the due date for lodgement of that activity statement.\n\ndigital currency exchange means an entity that provides trading platform/exchange for sellers and/or buyers of digital currency and provides exchange rates publicly.\n\ndigital currency website means a website that provides exchange rates publicly, without providing trading platform/exchange.\n\nexchange rate means the unit of digital currency in Australian dollars or the unit of digital currency in foreign currency.\n\nforeign currency means a currency other than Australian currency.\n\n    your particular exchange rate is:\n\n(a) If the exchange rate is quoted in Australian currency, the rate from a digital currency exchange, or a digital currency website, or the agreed rate, whichever you have chosen.\n\n(b) If the exchange rate is only quoted in foreign currency:\n\n    Step 1\n\nChoose an exchange rate with an amount expressed in a foreign currency from a digital currency exchange, or a digital currency website, or the agreed rate.\n\nStep 2\n\n    On the same day, convert the amount expressed in foreign currency (from Step 1) into Australian currency using the formula at paragraph 5 of [Goods and Services Tax: Foreign Currency Conversion Determination 2018.](https://www.legislation.gov.au/Details/F2018L00724)\n\ntransaction date means the date you use for digital currency conversion in your accounting system.\n\n    6. All other expressions in this Determination have the same meaning as in the GST Act.","sortOrder":4}],"analysis":{"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":false,"description":"The determination does not change which supplies are subject to GST. It only prescribes the method for converting amounts of consideration expressed in digital currency into Australian currency (valuation and timing rules) for GST calculation (s3–5)."},"complexity_factors":["Multiple conversion-day rules (different tests for cash v non-cash accounting and distinct rules for non-resident entities and limited registration entities) creating timing complexity (s5 definition of conversion day).","Choice and consistency obligation: taxpayer must select a single 'particular exchange rate' source (exchange, website, or agreed rate) and use it consistently (s4; s5).","Agreed rate exceptions: agreed rates are restricted to supplies under an agreement and must reflect arm’s-length rates between associates, introducing documentation and transfer-pricing risk (s5 agreed rate).","Foreign-currency-quoted digital currencies require a two-step conversion, referencing the Foreign Currency Conversion Determination (cross-instrument dependency increases compliance complexity) (s5 your particular exchange rate(b)).","Definitions of acceptable rate sources (digital currency exchange v website) but no mandated sources or central benchmark, leaving discretion to taxpayers and potential variability in applied rates (s5 definitions).","Record-keeping and audit risk: taxpayers must show chosen rate, consistency, and conversion-day selection, which imposes administrative burden.","Interaction with GST accounting method choices (cash v non-cash) can change taxable timing and amount, affecting cash flow and reporting."],"plain_english_summary":"This determination prescribes how to convert any part of a taxable supply priced in digital currency into Australian dollars for GST purposes: multiply the amount of digital currency by your chosen “particular exchange rate” and apply that rate consistently. It applies to suppliers and registered recipients with consideration expressed in digital currency (s3–5) and sets conversion-day rules that vary by accounting basis and residency, which determine the AUD value on which GST is calculated."},"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":5,"scope_assessment":{"changed":false,"description":"This determination maintains its original narrow scope: establishing conversion methodologies for digital currency to Australian currency for GST purposes. It does not expand beyond this technical administrative function."},"complexity_factors":["Multiple nested definitions for 'conversion day' with four distinct scenarios (non-cash accounting, cash accounting, non-resident non-limited, non-resident limited) each with sub-paragraphs and alternatives","Cross-reference to separate Foreign Currency Conversion Determination 2018 for Step 2 conversion when rates are quoted in foreign currency only","Conditional logic for 'agreed rate' requiring arm's length test when parties are associates","Dual-path calculation for exchange rates depending on whether quoted in AUD or foreign currency","8 defined terms in section 5 plus implicit reliance on GST Act definitions","Requirement for consistency in exchange rate choice without specifying enforcement mechanism"],"plain_english_summary":"This determination sets the official rules for converting cryptocurrency into Australian dollars for GST purposes, requiring businesses to use specified exchange rates and timing when reporting GST. \n\nIt affects any business that accepts digital currency (including non‑resident and limited‑registration sellers) and matters because it prevents selective rate‑picking, ensures consistent, auditable GST calculations, and reduces disputes with the ATO."}},"importantCases":[],"_links":{"self":"/api/acts/goods-and-services-tax-digital-currency-conversion-determination-2019","history":"/api/acts/goods-and-services-tax-digital-currency-conversion-determination-2019/history","analysis":"/api/acts/goods-and-services-tax-digital-currency-conversion-determination-2019/analysis","conflicts":"/api/acts/goods-and-services-tax-digital-currency-conversion-determination-2019/conflicts","importantCases":"/api/acts/goods-and-services-tax-digital-currency-conversion-determination-2019/important-cases","documents":"/api/acts/goods-and-services-tax-digital-currency-conversion-determination-2019/documents"}}