{"id":"F2017L00346","name":"Goods and Services Tax: (Particular Attribution Rules for Supplies and Acquisitions made through Agents) Determination 2017","slug":"goods-and-services-tax-particular-attribution-rules-for-supplies-and-acquisitions-made-through-agent","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":96056,"registerId":"commonwealth-F2017L00346-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Goods and Services Tax: (Particular Attribution Rules for Supplies and Acquisitions made through Agents) Determination 2017","content":"Legislative Instrument\n\nGoods and Services Tax: (Particular Attribution Rules for Supplies and Acquisitions made through Agents) 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\nSigned by Timothy Dyce\n\nDeputy Commissioner of Taxation\n\nDated: 28/03/2017\n\n    Name of determination\n\nThis determination is the Goods and Services Tax: (Particular Attribution Rules for Supplies and Acquisitions made through Agents) Determination 2017.\n\n    2. Commencement\n\nThis determination commences on the day after its registration on the Federal Register of Legislation.\n\n    3. Repeal of previous determination\n\nThis determination repeals and replaces determination A New Tax System (Goods and Services Tax) (Particular Attribution Rules for Supplies and Acquisitions made through Agents) Determination (No. 1) 2000 \\- F2006B11596 (previous determination), registered on 17 November 2006.  \n\n    4. Application\n\nThis determination applies to entities that make taxable supplies or creditable acquisitions through an agent and are reliant upon that agent for information to enable them to attribute their GST payable or input tax credit entitlement. The determination also applies to adjustments to those taxable supplies and creditable acquisitions.\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 makes taxable supplies or creditable acquisitions through an agent and is reliant upon that agent for information to enable them to attribute their GST payable or input tax credit entitlement will satisfy the requirements of the determination.\n\n    5. Particular attribution rules for GST payable on taxable supplies you make through an agent before you know the supplies have occurred\n\n(1) The GST payable by you on a taxable supply that you make through an agent upon whom you have to rely for information to enable you to attribute GST payable is attributable to the earlier of:\n\n(a) the tax period in which you, the principal, become aware that any of the consideration has been received; or\n\n(b) the tax period in which you, the principal, become aware that an invoice has been issued relating to the supply.\n\n(2) However, if you account on a cash basis, then:\n\n(a) if, in a tax period, you, the principal, become aware that all of the consideration has been received for a taxable supply – the GST payable on the supply is attributable to that tax period; or\n\n(b) if, in a tax period, you, the principal, become aware that part of the consideration has been received for a taxable supply – the GST payable on the supply is attributable to that tax period, but only to the extent of the consideration that you, the principal, become aware has been received; or\n\n(c) if, in a tax period, you, the principal, are not aware that any of the consideration has been received for a taxable supply – none of the GST payable on the supply is attributable to that tax period.  \n  \n  \n  \n\n6. Particular attribution rules for input tax credits that arise on creditable acquisitions that you make through an agent before you know the acquisitions have occurred\n\n(1) The input tax credit to which you are entitled for a creditable acquisition that you make through an agent upon whom you have to rely for information to enable you to attribute the input tax credit is attributable to the earlier of:\n\n(a) the tax period in which you, the principal, become aware that any of the consideration has been provided; or\n\n(b) the tax period in which you, the principal, become aware that an invoice has been issued relating to the acquisition.\n\n(2) However, if you account on a cash basis, then:\n\n(a) if, in a tax period, you, the principal, become aware that you have provided all of the consideration for a creditable acquisition – the input tax credit for the acquisition is attributable to that tax period; or\n\n(b) if, in a tax period, you, the principal, become aware that you have provided part of the consideration – the input tax credit for the acquisition is attributable to that tax period, but only to the extent of the consideration that you, the principal, are aware you have provided in that tax period; or\n\n(c) if, in a tax period, you, the principal, are not aware that you have provided any of the consideration, none of the input tax credit for the acquisition is attributable to that tax period.\n\n7. Particular attribution rules for Adjustments\n\n(1) An adjustment you have in relation to a supply or acquisition made through an agent upon whom you have to rely for information to attribute the adjustment, is attributable to the tax period in which you, the principal, become aware of the adjustment.\n\n(2) However, if you account on a cash basis, and the adjustment arises from an adjustment event as a result of which you are liable to provide consideration, then:\n\n(a) if, in a tax period, you, the principal, become aware that you have provided all the consideration – the adjustment is attributable to that tax period; or\n\n(b) if, in a tax period, you, the principal, become aware that you have provided part of the consideration – the adjustment is attributable to that tax period, but only to the extent of the consideration that you, the principal, are aware you have provided in that tax period; or\n\n(c) if, in a tax period, you, the principal, are not aware that any of the consideration has been provided – none of the adjustment is attributable to that tax period.\n\n    8. No intention to over-ride other provisions  \n    To avoid doubt, this Determination is not intended to override subsection 29‑10(3), subsection 29-20(3), Division 57, Division 153 or Division 156 of the GST Act.\n    9. 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"},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":false,"description":"The instrument repeals and replaces the previous determination but states it is substantially the same (s 3, s 4). It continues to apply to principals who make taxable supplies or creditable acquisitions through agents and who rely on those agents for information; no expansion or narrowing of scope is indicated in the text."},"complexity_factors":["Attribution depends on the principal 'becoming aware' of receipt/provision of consideration or invoice — a subjective timing standard that creates uncertainty for reporting periods (ss 5(1), 6(1), 7(1)).","Separate, pro‑rata rules for cash‑basis taxpayers require tracking partial receipts or payments and allocating GST or input tax credits to the extent of known consideration (ss 5(2), 6(2), 7(2)).","Adjustments follow the same awareness timing and cash‑basis splitting, adding another layer of timing and apportionment for later events (s 7).","Rule applies only where principals rely on an agent for information, concentrating compliance and monitoring burdens on principals while operational control rests with agents (s 4).","The determination expressly does not override specified GST Act provisions, so interaction and potential complexity arise with other attribution and adjustment rules (s 8).","Administrative transition is minimal: it repeals and replaces the 2000/2006 determination and states it is substantially the same, limiting scope change but requiring practitioners to confirm continuity (s 3, s 4)."],"plain_english_summary":"This determination sets when GST and input tax credits are attributed for supplies or acquisitions made through an agent whose information the principal relies on. Tax is attributable to the earlier of the tax period when the principal becomes aware that consideration was received/provided or when an invoice is issued, with cash‑basis and adjustment exceptions.\n\nIt affects principals using agents: they bear the timing risk, must improve monitoring and records, and may apportion amounts when only partial consideration is known."},"kimi_summary":{"content_quality":"ok","complexity_score":4,"scope_assessment":{"changed":false,"description":"This is a straightforward remake of a 2000 determination with the same scope. Section 4 explicitly states it is 'substantially the same as the previous determination' and ensures continuity for entities already relying on the old rules. No expansion of scope beyond the original purpose of providing attribution rules for principal-agent GST arrangements."},"complexity_factors":["Multiple conditional branches: separate rules for GST payable (section 5), input tax credits (section 6), and adjustments (section 7)","Nested exceptions within each section: primary rule followed by 'However' clauses for cash basis accounting with three sub-conditions each (a, b, c)","Cross-references to GST Act provisions in section 8 (subsections 29-10(3), 29-20(3), Divisions 57, 153, 156)","Defined terms rely entirely on external legislation ('Expressions in this Determination have the same meaning as in the GST Act')","Substantive content spans only 7 operative sections with repetitive structure across sections 5, 6, and 7"],"plain_english_summary":"This Determination sets special timing rules for GST reporting and input tax credits where businesses use agents to transact on their behalf. Instead of the normal invoice/payment timing, GST is attributed to the tax period when the principal actually becomes aware of payments or invoices through the agent.\n\nIt affects principals and their agents (including cash-basis businesses), preventing principals from being penalised for late reporting when they genuinely did not know about agent-handled transactions."}},"importantCases":[],"_links":{"self":"/api/acts/goods-and-services-tax-particular-attribution-rules-for-supplies-and-acquisitions-made-through-agent","history":"/api/acts/goods-and-services-tax-particular-attribution-rules-for-supplies-and-acquisitions-made-through-agent/history","analysis":"/api/acts/goods-and-services-tax-particular-attribution-rules-for-supplies-and-acquisitions-made-through-agent/analysis","conflicts":"/api/acts/goods-and-services-tax-particular-attribution-rules-for-supplies-and-acquisitions-made-through-agent/conflicts","importantCases":"/api/acts/goods-and-services-tax-particular-attribution-rules-for-supplies-and-acquisitions-made-through-agent/important-cases","documents":"/api/acts/goods-and-services-tax-particular-attribution-rules-for-supplies-and-acquisitions-made-through-agent/documents"}}