{"id":"F2017L00425","name":"Goods and Services Tax: Particular Attribution Rules Where Total Consideration Not Known Determination 2017","slug":"goods-and-services-tax-particular-attribution-rules-where-total-consideration-not-known-determinatio","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":96173,"registerId":"commonwealth-F2017L00425-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 Where Total Consideration Not Known Determination 2017","content":"Legislative Instrument\n\nGoods and Services Tax: Particular Attribution Rules Where Total Consideration is Not Known 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: 12/04/2017\n\n    Name of determination\n\nThis determination is the Goods and Services Tax: Particular Attribution Rules Where Total Consideration Not Known Determination 2017.\n\n    2. Commencement\n\n    This determination commences on 1 April 2017.\n\n    3. Repeal of previous determination\n\nThis determination replaces A New Tax System (Goods and Services Tax) (Particular Attribution Rules Where Total Consideration Not Known) Determination (No. 1) 2000 \\- F2006B11593 (previous determination), registered on 17 November 2006. The previous determination is repealed from 1 April 2017.\n\n    4. Application\n\n    (1) This determination applies where you make a taxable supply or creditable acquisition and:\n    (a) you do not know the total consideration when any part of the consideration is paid or received or when an invoice is issued relating to the supply or acquistion,, and\n    (b) the ascertainment of the total consideration depends on a future event or events that is not entirely within your control\n\nand either:\n\n    (c) an invoice is issued relating to the supply or acquisition; or\n    (d) any consideration is received or paid for the supply or acquisition.\n    (2) This determination applies only if you do not account on a cash basis.\n\n    (3) This determination is substantially the same as the determination that it replaces.. An entity that satisfied the requirements of the previous determination and makes a taxable supply or creditable acquisition as described in this determination will satisfy the requirements of this determination.\n\n    5. Particular attribution rule for GST payable on a taxable supply occurring before the supplier knows the total consideration\n\n(1) Where, in a tax period, you make a taxable supply before you know the total consideration, and an invoice is issued relating to the taxable supply which states an amount of consideration and:\n\n(a) no consideration is received for the supply in that tax period – the GST on the supply is attributable to that tax period but only to the extent of the amount of the consideration stated in the invoice, or\n\n(b) consideration is received for the supply in that tax period – the GST on the supply is attributable to that tax period but only to the extent:\n\n(i) where the consideration received is less than or equal to the amount of the consideration stated in the invoice – the amount of consideration stated in the invoice, or\n\n(ii) where the consideration received is more than the amount stated in the invoice – the amount of the consideration received.\n\n(2) Where, in a tax period, you make a taxable supply before you know the total consideration, and an invoice is not issued relating to the supply and:\n\n(a) consideration is received for the supply in that tax period – the GST payable on the taxable supply is attributable to that tax period but only to the extent of the consideration received in that tax period, or\n\n(b) no consideration is received for the supply in that tax period – none of the GST on the supply is attributable to that tax period.\n\n(3) In tax periods after the tax period in which you first attributed any GST on the taxable supply, attribute GST on any increase in consideration to the earlier of the tax period (or tax periods) in which you issue an invoice (or amended invoice) for the increase in consideration or receive any of the additional consideration.\n\n6. Particular attribution rule for input tax credits arising from a creditable acquisition occurring before the recipient knows the total consideration\n\n(1) Where, in a tax period, you make a creditable acquisition before you know the total consideration, and an invoice is issued relating to the creditable acquisition which states an amount of consideration and you:\n\n(a) do not provide any of the consideration for the acquisition in that tax period – the input tax credit for the acquisition is attributable to that tax period but only to the extent of the amount of the consideration stated on the invoice, or\n\n(b) provide any of the consideration for the acquisition in that tax period – the input tax credit for the creditable acquisition is attributable to that tax period but only to the extent:\n\n(i) where the consideration provided by you is less than or equal to the amount of the consideration stated in the invoice - the amount of the consideration stated in the invoice, or\n\n(ii) where the consideration provided by you is more than the amount stated in the invoice - the amount of the consideration provided.\n\n(2) Where, in a tax period, you make a creditable acquisition before you know the total consideration, and an invoice is not issued relating to a creditable acquisition and you:\n\n(a) provide any of the consideration for the acquisition in that tax period – the input tax credit for the creditable acquisition is attributable to that tax period but only to the extent of the consideration that you provided in that tax period, or\n\n(b) provide none of the consideration for the acquisition in that tax period – none of the input tax credit for the acquisition is attributable to that tax period.\n\n(3) In tax periods after the tax period in which you first attributed any GST on the taxable supply, attribute GST on any increase in consideration to the earlier of the tax period (or tax periods) in which you issue an invoice (or amended invoice) for the increase in consideration or receive any of the additional consideration.\n\n(4) However, the input tax credit to which you are entitled for a creditable acquisition is attributable to the tax period in which you first know the total amount of consideration for the creditable acquisition to the extent it has not been attributed to an earlier tax period.\n\n(5) To avoid doubt, this Determination is not intended to override subsection 29-10(3) of the GST Act\n\n    7. Definitions\n\nExpressions in this determination have the same meaning as in the GST Act.","sortOrder":0}],"analysis":{"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":false,"description":"The determination replaces the prior 2000 instrument but expressly states it is substantially the same (ss 3, 4(3)). It therefore does not materially change which supplies or acquisitions are covered; it clarifies timing and attribution mechanics for non-cash-basis taxpayers when total consideration is unknown (ss 4, 5, 6)."},"complexity_factors":["Multiple conditional branches depending on whether an invoice exists and whether any consideration is paid/received (see ss 5(1)–(2), 6(1)–(2)).","Different attribution rules for suppliers (GST payable) and recipients (input tax credits), including a rule that later attributes increases when invoices/consideration occur (ss 5(3), 6(3)).","Exclusion of cash-basis taxpayers narrows scope but requires taxpayers to determine accounting basis (s 4(2)).","Interplay with final attribution when the total consideration is first known, and an express saving for subsection 29-10(3) of the GST Act (s 6(4) and note at s 6(5)).","Requirement that total consideration depends on future events not entirely within the taxpayer’s control (s 4(1)(b)) — introduces factual judgments about control and timing.","Replacement of an earlier instrument while stating substantive continuity, requiring cross-checking against prior practice (s 3 and s 4(3)).","Precision needed in tax-period timing and amended invoices to trigger attribution (ss 5(3), 6(3))."],"plain_english_summary":"This determination sets rules for when GST and input tax credits must be reported if the total price for a supply or acquisition isn’t known when part payments are made or invoices issued. It applies to taxpayers who do not use the cash basis and ties attribution to invoices or amounts paid/received, with adjustments once total consideration becomes known. It matters because it fixes the timing for GST reporting and credit claims, affecting business cash flow and record-keeping."},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"},"kimi_summary":{"content_quality":"ok","complexity_score":6,"scope_assessment":{"changed":false,"description":"This is a direct replacement of a 2000 determination with substantially the same scope. Section 3(3) explicitly states it is 'substantially the same as the determination that it replaces.' The instrument maintains the original narrow purpose of providing attribution rules for GST transactions with uncertain consideration."},"complexity_factors":["Nested conditional logic with multiple branches (sections 5 and 6 each contain 2-3 subsections with further nested clauses (a), (b), and sub-clauses (i) and (ii))","Cross-references to the GST Act (subsections 29-25(1), 29-10(3)) without reproducing their content","Dual parallel structures for suppliers (section 5) and recipients (section 6) that must be read together but have subtle differences","Temporal sequencing requirements across multiple tax periods requiring tracking of 'first attribution' and subsequent adjustments","Defined terms imported by reference from the GST Act rather than defined in the instrument itself","Exception in section 6(4) creating a 'catch-all' attribution rule that operates differently from the main scheme","Specific exclusion in section 6(5) clarifying non-override of existing statutory provision"],"plain_english_summary":"This rule tells Australian businesses (not on cash-basis accounting) when to report GST on sales or purchases whose final price is uncertain. It treats GST as reportable based on issued invoices or payments as they occur, with any adjustments or additional GST/credits reported once the final price is known. It gives suppliers and recipients certainty on timing so they don’t delay or guess GST treatment."}},"importantCases":[],"_links":{"self":"/api/acts/goods-and-services-tax-particular-attribution-rules-where-total-consideration-not-known-determinatio","history":"/api/acts/goods-and-services-tax-particular-attribution-rules-where-total-consideration-not-known-determinatio/history","analysis":"/api/acts/goods-and-services-tax-particular-attribution-rules-where-total-consideration-not-known-determinatio/analysis","conflicts":"/api/acts/goods-and-services-tax-particular-attribution-rules-where-total-consideration-not-known-determinatio/conflicts","importantCases":"/api/acts/goods-and-services-tax-particular-attribution-rules-where-total-consideration-not-known-determinatio/important-cases","documents":"/api/acts/goods-and-services-tax-particular-attribution-rules-where-total-consideration-not-known-determinatio/documents"}}