{"id":"F2020L00046","name":"Goods and Services Tax: Waiver of Tax Invoice Requirement (Visa Purchasing Card) Determination 2020","slug":"goods-and-services-tax-waiver-of-tax-invoice-requirement-visa-purchasing-card-determination-2020","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":100596,"registerId":"commonwealth-F2020L00046-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Goods and Services Tax: Waiver of Tax Invoice Requirement (Visa Purchasing Card) Determination 2020","content":"Legislative Instrument\n\nGoods and Services Tax: Waiver of Tax Invoice Requirement (Visa Purchasing Card) Determination 2020\n\nI, Louise Clarke, Deputy Commissioner of Taxation, Policy, Analysis and Legislation, make this determination under subsection 29-10(3) of the A New Tax System (Goods and Services Tax) Act 1999.\n\nLouise Clarke\n\nDeputy Commissioner of Taxation\n\nDated: 2/12/2019\n\n1.  Name of determination\n\nThis determination is the Goods and Services Tax: Waiver of Tax Invoice Requirement (Visa Purchasing Card) Determination 2020.\n\n2. Commencement\n\nThis determination commences on the day after it is registered on the Federal Register of Legislation.\n\n3. Repeal of previous determination\n\nThis determination repeals and replaces Goods and Services Tax: Waiver of Tax Invoice Requirement (Visa Purchasing Card) Determination 2018 (F2018L01354) registered on 27 September 2018.\n\n4. Definitions\n\n(1) The following expressions are defined for the purposes of this determination:\n\nCardholder is the entity participating in an arrangement under which the Visa Purchasing Card is issued to that entity, or other entities at its request.\n\nData matching provider means:\n\n(a) Visa International, or\n\n(b) a Visa Purchasing Card provider, or\n\n(c) an entity authorised by Visa International and/or a Visa Purchasing Card provider, or\n\n(d) any of the entities in paragraphs (a), (b), and (c) working in combination.\n\nElectronic purchasing system is a computer based system that:\n\n(a) allows a cardholder to initiate the acquisition of supplies by transmission of an electronic based purchase order to the supplier\n\n(b) records information in relation to acquisitions made by the cardholder, and\n\n(c) ensures that functions mentioned in paragraph (a) and (b) are undertaken in an accurate and reasonably secure manner.\n\nGST Act means the A New Tax System (Goods and Services Tax) Act 1999.\n\nMatched data file is a file that is produced and issued by the data matching provider that meets the following requirements:\n\n(a) the data matching provider must produce and issue the file under secure systems and control mechanisms satisfying the ongoing security requirements of the Visa Purchasing Card provider or Visa International, and\n\n(b) the file must only contain transactions where the issuer's transaction data and the purchase order data file have been positively matched using the following data fields:\n\n(i) the supplier's name or identification number\n\n(ii) the purchasing card number\n\n(iii) the price, and\n\n(iv) the date.\n\nQualifying cardholder is a cardholder that satisfies paragraph (a) or (b), or paragraphs (c) and (d):\n\n(a) the cardholder is a government related entity, or\n\n(b) in respect of the cardholder, either:\n\n(i) a determination under section 27-15 of the GST Act is in effect, or\n\n(ii) a determination under section 27-15 of the GST Act would have been in effect if paragraphs 188‑15(1)(a), 188-15(2)(b), 188‑20(1)(a) or 188‑20(2)(b) of the GST Act did not apply, or\n\n(c) one of the following applies:\n\n(i) the cardholder satisfies or could satisfy the membership requirements of a GST group set out in section 48-10 of the GST Act, or\n\n(ii) the cardholder is nominated in a written agreement for the formation of a GST joint venture made under paragraph 51‑5(1)(ea) of the GST Act to be the joint venture operator of the joint venture, or\n\n(iii) the cardholder is nominated as the joint venture operator of the joint venture under paragraph 51-70(1)(c) of the GST Act, and\n\n(d) in respect of the cardholder or any relevant entity, either:\n\n(i) a determination under section 27-15 of the GST Act is in effect, or\n\n(ii) a determination under section 27-15 of the GST Act would have been in effect if paragraphs 188-15(1)(a), 188-15(2)(b), 188‑20(1)(a) or 188-20(2)(b) of the GST Act did not apply.\n\nRelevant entity means an entity that:\n\n(a) satisfies or could satisfy the membership requirements of the same GST group as a cardholder\n\n(b) is a participant in the same GST joint venture as a cardholder, or\n\n(c) is or could be a member of a GST group of which an entity referred to in paragraph (b) is also or could also be a member.\n\nSupplier includes an agent through whom the supplier makes a supply.\n\nVisa International means the Visa International Service Association Inc.\n\nVisa Purchasing Card is a Visa International branded card or account that is issued to and in the name of an entity (or other entities as requested) and is used to purchase goods and services for commercial purposes.\n\nVisa Purchasing Card provider is an entity that issues Visa Purchasing Cards or an entity authorised to provide Visa Purchasing Cards.\n\n(2) Other expressions in this determination have the same meaning as in the GST Act.\n\n5. Relief from requirement to hold a tax invoice\n\nFor the purposes of attributing an input tax credit for a creditable acquisition to a tax period, a cardholder is not required (under subsection 29-10(3) of the GST Act) to hold a tax invoice for the creditable acquisition if all the requirements in section 6 of this determination are satisfied.\n\n6. Requirements for relief from holding a tax invoice\n\n(1) At the time the cardholder gives its GST return/Business Activity Statement for the tax period to the Commissioner:\n\n(a) the cardholder must hold a matched data file that records a transaction which includes the creditable acquisition and meets the matched data file information requirements set out in section 7\n\n(b) the cardholder must meet all the requirements of section 13, and\n\n(c) section 14 must not require the cardholder to hold a tax invoice in relation to the acquisition.\n\n(2) For the matched data file referred to in subsection 4(1), the data matching provider must:\n\n(a) meet the data matching provider requirements set out in section 12, and\n\n(b) where any of the matched data file information specified in paragraph 7(d) for a particular supply is provided by the cardholder to the data matching provider, the cardholder-data method must be used in accordance with section 8.\n\n7. Matched data file information requirements\n\nThe matched data file must include:\n\n(a) the date of issue of the matched data file\n\n(b) the identity or ABN of the cardholder\n\n(c) the name(s) of the person(s) or department(s) that uses the Visa Purchasing Card to purchase the creditable acquisition\n\n(d) for the particular creditable acquisition:\n\n(i) the date the cardholder acquired the supply\n\n(ii) the identity of the supplier\n\n(iii) the ABN of the supplier\n\n(iv) the Branch Registration Number of the supplier (where applicable)\n\n(v) a brief description of the supply or, if that is not available, a description or recognised code identifying the supplier's industry\n\n(vi) the GST payable, and\n\n(vii) the total amount paid.\n\n8. Use of the cardholder-data method for obtaining matched data file information\n\nTo use the cardholder-data method:\n\n(a) the cardholder must be a qualifying cardholder\n\n(b) the particular supply recorded on the matched data file must only have been acquired and recorded by way of an electronic purchasing system, and\n\n(c) the requirements in sections 9, 10 and 11 must be satisfied.\n\n9. Cardholder-data method - information supplier must provide to qualifying cardholder\n\nThe supplier must have provided the following details to the qualifying cardholder for recording on the electronic purchasing system:\n\n(a) the identity of the supplier\n\n(b) the ABN of the supplier\n\n(c) the Branch Registration Number of the supplier (where applicable)\n\n(d) in relation to each potential supply that can be acquired via the electronic purchasing system:\n\n(i) a brief description of the potential supply\n\n(ii) the amount of GST to be paid, and\n\n(iii) the total price to be paid.\n\n10. Cardholder-data method - information supplier or cardholder must provide to data matching provider\n\nThe supplier or the qualifying cardholder must provide the data matching provider with:\n\n(a) the ABN of the supplier, and\n\n(b) the Branch Registration Number of the supplier (where applicable).\n\n11. Cardholder-data method - qualifying cardholder and purchase order information requirements\n\nPurchase order information requirements\n\n(1) For each acquisition initiated via the electronic purchasing system, the qualifying cardholder must provide a purchase order to the supplier that contains the following information:\n\n(a) full or partial Visa Purchasing Card number\n\n(b) date of the purchase order\n\n(c) the identity of the supplier\n\n(d) the ABN of the supplier\n\n(e) the Branch Registration Number of the supplier (if applicable)\n\n(f) the identity or the ABN of the recipient\n\n(g) a brief description of each thing supplied\n\n(h) for each description, the quantity of the goods or the extent of the services supplied\n\n(i) the price of the supply, and\n\n(j) the amount of GST payable.\n\nQualifying cardholder requirements\n\n(2) A qualifying cardholder must also satisfy the following requirements:\n\n(a) the qualifying cardholder must provide the following purchase order data from each purchase order to the data matching provider:\n\n(i) the date of the purchase order\n\n(ii) the purchasing card number of the qualifying cardholder\n\n(iii) the identity or the ABN of the supplier\n\n(iv) a brief description of each thing supplied\n\n(v) the price of the supply, and\n\n(vi) the amount of GST payable.\n\n(b) the qualifying cardholder must reasonably comply with its obligations under the taxation laws, and\n\n(c) the qualifying cardholder will transmit purchase order data to the data matching provider pursuant to a written agreement that the qualifying cardholder has with the supplier. The agreement must specify the supplies which will be made via the electronic purchasing system and contain the following terms:\n\n(i) the qualifying cardholder and the supplier agree that the qualifying cardholder will transmit purchase order data to the data matching provider\n\n(ii) the supplier and the qualifying cardholder must be registered for GST at the time that the supplier makes the supply recorded on the matched data file\n\n(iii) the supplier acknowledges that it will notify the qualifying cardholder if it ceases to be registered for GST, and\n\n(iv) if the supplier issues a tax invoice that relates to a supply specified in the agreement, the supplier agrees that the tax invoice will be marked prominently or be easily identifiable as having resulted from an electronic purchasing system transaction.\n\n12. Data matching provider requirements for matched data files\n\n(1) Where the data matching provider has reason to consider any information set out in paragraph 7(d) is not accurate, the data matching provider must not include that information in the matched data file.\n\n(2) The data matching provider must retain a copy of the matched data file for a period of 5 years from the date of the last supply recorded on that file.\n\n13. Cardholder requirements\n\nThe cardholder must have in place:\n\n(a) an effectively regulated corporate policy (that includes the retention of documentary evidence) for determining the extent of creditable purpose for acquisitions made on the Visa Purchasing Card that are wholly or partly of a private or domestic nature, and\n\n(b) an effectively regulated corporate policy that ensures a tax invoice and the matched data file are not incorrectly used to claim input tax credits twice for a single creditable acquisition.\n\n14. Situations where a tax invoice is still required\n\nThe cardholder must hold a tax invoice before attributing input tax credits to a tax period (if required by subsection 29-10(3) of the GST Act) for a creditable acquisition recorded on a matched data file where:\n\n(a) if the cardholder-data method is used, a requirement set out in section 8 is not satisfied in relation to that supply, or\n\n(b) there is an error on the matched data file in relation to that acquisition.\n\n15. Reimbursement of employees etc\n\nIf the cardholder has a creditable acquisition because of section 111-5 of the GST Act:\n\n(a) they are taken to meet the requirements of paragraph 6(1)(a) if they hold a matched data file that includes the details at section 7 for the expense for which reimbursement is paid, and\n\n(b) any reference to a creditable acquisition in section 7 is taken to be a reference to the expense for which reimbursement is paid.","sortOrder":0}],"analysis":{"flash_summary":{"complexity_score":6,"scope_assessment":{"changed":false,"description":"This instrument expressly repeals and replaces the 2018 Visa Purchasing Card waiver (section 3) but, on its face, continues the same core function: waiving the tax‑invoice holding requirement under subsection 29-10(3) of the GST Act where a matched data file and the listed conditions are satisfied (see section 5). The determination does not itself state any expansion or narrowing of entitlement beyond those detailed conditions; any change from the prior instrument cannot be inferred from this text alone."},"complexity_factors":["Eligibility depends on layered definitions and cross-references to the GST Act (definition of qualifying cardholder and relevant entity) (see Definitions and section 4).","Detailed content and format requirements for the matched data file, including multiple specific fields (section 7).","Alternative 'cardholder-data method' with extra conditions tying electronic purchasing systems, supplier‑provided data and written agreements together (sections 8–11).","Obligations and discretion for the data matching provider to exclude inaccurate items and retain files for five years (section 12) impose operational and recordkeeping burdens.","Cardholder corporate policy requirements to determine creditable purpose and prevent double claiming (section 13) create internal compliance controls and potential audit exposure.","Exceptions where a traditional tax invoice is still required or where errors negate relief introduce conditional complexity (section 14).","Interaction with the GST Act (subsection 29-10(3) and sections referenced in qualifying-cardholder tests) requires legal interpretation and alignment with existing tax obligations (sections 5 and Definitions).","Repeal and replacement of the 2018 determination adds a procedural element to implementation, requiring stakeholders to check for any practical or administrative differences (section 3)."],"plain_english_summary":"This determination lets eligible organisations use a secure “matched data file” instead of holding a supplier tax invoice to claim GST input tax credits for purchases made on Visa Purchasing Cards, provided detailed conditions are met. It affects cardholders (notably government-related entities, GST groups/joint ventures), suppliers, Visa or authorised data-matching providers and obliges corporate policies and electronic purchasing controls. It matters because it replaces a paper invoice requirement with a data‑matching regime that shifts compliance effort onto cardholders, suppliers and data providers."},"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":7,"scope_assessment":{"changed":false,"description":"This is a straightforward remaking of a 2018 determination with the same scope and purpose. It maintains the existing framework for waiving tax invoice requirements for Visa Purchasing Card users without expanding into new card types, new categories of users, or new compliance frameworks. The structure and substantive content appear consistent with the original 2018 instrument it replaces."},"complexity_factors":["14 defined terms in section 4, including complex nested definitions like 'qualifying cardholder' which has four alternative pathways (a, b, c+d) with multiple sub-paragraphs","Heavy cross-referencing to the GST Act (A New Tax System (Goods and Services Tax) Act 1999), including specific sections like 27-15, 48-10, 51-5, 51-70, 111-5, and 188-15/188-20","Conditional logic with multiple layers: section 6 requires satisfaction of section 7 AND section 13 AND negative condition in section 14; section 8 requires (a) AND (b) AND (c)","Dual-track system with different requirements for standard method vs cardholder-data method (sections 8-11)","Exception to exception structure: section 5 provides relief, section 14 creates exceptions to that relief, and section 6(1)(c) incorporates section 14 as a negative condition","Complex eligibility criteria for 'qualifying cardholder' involving hypothetical scenarios ('would have been in effect if paragraphs... did not apply') and membership of GST groups/joint ventures","Multiple parties with interlocking obligations: cardholder, supplier, data matching provider, and qualifying cardholder each have specific duties under sections 9-13","Documentary requirements spread across 7 different sections (6-12) with specific data fields required in matched data files (7 items in section 7, 6 items in section 11(2)(a))","Incorporation of external standards ('secure systems and control mechanisms satisfying the ongoing security requirements of the Visa Purchasing Card provider')"],"plain_english_summary":"This determination lets eligible businesses using Visa Purchasing Cards claim GST input tax credits without traditional tax invoices by relying on secure “matched data files” that electronically pair cardholder and supplier transaction data. It mainly affects government bodies, large corporate cardholders, suppliers, and Visa/issuers or their agents who produce these records. The change cuts paperwork for high-volume purchasers while requiring strict data-matching, retention, security, and anti-double-claim safeguards to protect tax integrity."}},"importantCases":[],"_links":{"self":"/api/acts/goods-and-services-tax-waiver-of-tax-invoice-requirement-visa-purchasing-card-determination-2020","history":"/api/acts/goods-and-services-tax-waiver-of-tax-invoice-requirement-visa-purchasing-card-determination-2020/history","analysis":"/api/acts/goods-and-services-tax-waiver-of-tax-invoice-requirement-visa-purchasing-card-determination-2020/analysis","conflicts":"/api/acts/goods-and-services-tax-waiver-of-tax-invoice-requirement-visa-purchasing-card-determination-2020/conflicts","importantCases":"/api/acts/goods-and-services-tax-waiver-of-tax-invoice-requirement-visa-purchasing-card-determination-2020/important-cases","documents":"/api/acts/goods-and-services-tax-waiver-of-tax-invoice-requirement-visa-purchasing-card-determination-2020/documents"}}