Goods and Services Tax: Waiver of Tax Invoice Requirement (Corporate Card Statements) No. 2 Determination 2020

Corporate card: A card or account (physical card not required) issued to and in the name of an entity (or other entities at its request) intended for commercial purchases. This covers standard corporate credit cards, fuel cards, and travel cards. The definition is broad, including accounts where no plastic card is issued.

Cardholder: The entity that participates in the arrangement under which the corporate card is issued to it or to others at its request. Notably, the cardholder is the entity that claims the ITC, not necessarily the individual employee or officer who physically uses the card.

Corporate card provider: An entity explicitly listed in section 5 (e.g., American Express Australia Limited, Cabcharge Australia Limited, Diners Club, MasterCard and Visa issuers, Lufthansa AirPlus, Wex Fuel Cards, Qantas, Mobil Oil) or an entity authorised by a listed provider to offer their corporate card products. This is a closed list subject to amendment but currently covers major credit card schemes and niche fuel/travel card networks.

Corporate card statement: A statement for a corporate card issued by or on behalf of a provider, including electronic data files of transactions and statements issued periodically or on demand. The definition encompasses the digital feeds that businesses typically download for expense management.

Relief from holding a tax invoice: Under section 6, a cardholder is not required (by subsection 29-10(3) of the GST Act) to hold a tax invoice for a creditable acquisition if all requirements in section 8 are satisfied. Section 8 then imposes three cumulative conditions: the cardholder holds a corporate card statement meeting the information requirements of section 9; the cardholder meets the requirements of section 13 (corporate policies); and the creditable acquisition is not one where an ‘estimated GST amount’ was calculated under subsection 11(b).

Corporate card statement information requirements (section 9): The statement must enable the cardholder to ascertain: the date of issue of the statement; the identity or ABN of the cardholder; the name(s) of the person/department using the card (or vehicle identifier for fuel cards); and for each transaction: the date of acquisition, identity of supplier (or driver ID for taxi travel), the supplier’s ABN and branch registration number (if applicable), a brief description of the supply (or a description/industry code), the GST payable, and the total amount paid.

Signed statement method (sections 10-11): A method by which the corporate card provider/acquirer can use a signed statement from a supplier to calculate GST payable or an estimated GST amount. Where the supplier declares it makes only taxable supplies at 1/11th of the price, the provider may calculate GST as 1/11th automatically. For mixed-transaction suppliers or those where GST is not at 1/11th, the provider may calculate an estimated GST amount (also at 1/11th of the price of the relevant transaction) but must indicate on the statement that the amount must be verified. The cardholder is then advised to obtain a tax invoice before claiming the ITC if required by subsection 29-10(3).

Estimated GST amount: A calculated GST figure that is not guaranteed accurate. The instrument excludes transactions with such amounts from the waiver (section 8(1)(c)). This prevents reliance on the statement for those items; the cardholder must either seek a tax invoice or forgo the ITC in that period.

Accuracy requirements (section 12): Where the corporate card provider has reason to consider any information in section 9(d) or an estimated GST amount is not accurate, the provider must not include that information on the statement. This imposes a positive duty to exclude known inaccuracies.

Mixed transaction supplier: A supplier that has indicated on a signed statement that it provides taxable supplies as well as GST-free and/or input taxed supplies. Such suppliers cannot use the simple 1/11th calculation; their GST payable depends on the mix of supplies.

The determination directly affects three categories of entities: cardholders, corporate card providers and acquirers, and suppliers who accept corporate cards and provide signed statements. Indirectly, it affects employees and other individuals who use corporate cards on behalf of the cardholder and who may seek reimbursement.

Cardholders: These are entities (typically businesses, government agencies, or non-profit organisations) that use corporate cards for commercial purchases. The relief is expressly for cardholders; they are the ones who claim input tax credits. The instrument shifts their compliance burden from collecting individual tax invoices to maintaining an ‘effectively regulated corporate policy’ for determining the extent of creditable purpose (especially for mixed-use acquisitions) and for ensuring that the same transaction is not claimed twice. This affects finance and accounts payable teams who must design, implement, and audit these policies. Smaller businesses without dedicated compliance resources may find the policy requirement disproportionately costly relative to the benefit of avoiding invoice collection. For large enterprises with automated expense management systems, the relief can significantly reduce processing costs.

Corporate card providers and acquirers: The listed providers (American Express, Diners Club, Visa/MasterCard issuers, Cabcharge, etc.) and entities they authorise must adjust their statement production processes to ensure that statements meet the information requirements of section 9. They must have ‘an accurate method of obtaining or calculating the transaction information specified in subsection 9(d)’ (section 8(2)(b)). They may choose to use the signed statement method, which requires them to obtain and retain signed statements from suppliers for at least five years after the supplier ceases association. The accuracy requirement in section 12 imposes liability for including known inaccuracies; providers must have systems to flag and exclude dubious data. This creates a cost for providers to manage supplier relationships and data quality.

Acquirers: Entities that sign merchants and are responsible for settlement. They are included in the definition of ‘corporate card provider/acquirer’ and share the obligations regarding signed statements and accuracy. They interact directly with suppliers to obtain the signed statements.

Suppliers: Businesses that accept corporate cards as payment. If they choose to participate in the signed statement method, they must provide a statement to the corporate card provider/acquirer that includes their ABN, branch registration number, the type of supplies they make (taxable, GST-free, input taxed), and, where they make only taxable supplies, whether GST is calculated at 1/11th for all supplies. They must also undertake to notify the provider if they cease to be registered for GST or if their supply type changes. This is a one-time paperwork burden, but the undertaking to notify creates ongoing compliance risk if they forget.

Employees and reimbursement: Section 14 addresses reimbursements under section 111-5 of the GST Act. If an employee incurs an expense on a corporate card and is reimbursed, the cardholder (employer) is treated as having made a creditable acquisition. For the waiver to apply, the cardholder must hold a corporate card statement that includes the details in section 9 for that expense. This extends the relief to the reimbursement scenario, but the reliance remains on the statement rather than the employee’s receipt.

ATO: The Commissioner of Taxation is indirectly affected as the administrator. The determination reduces the volume of tax invoices the ATO would otherwise review in audits, but replaces it with the need to verify corporate card statement compliance and the adequacy of cardholders’ corporate policies. This may shift audit focus from transaction-level evidence to systemic controls.

Wider economy: The instrument reduces transaction costs for businesses that use corporate cards extensively, which may encourage greater use of card payments over other forms of payment (e.g., cash, EFT) for business purchases. That could have minor effects on payment system efficiency and merchant costs, but the primary effect is on compliance costs within the GST system.

Rights: The principal right conferred is the right of a cardholder to claim an input tax credit in a tax period without holding a tax invoice, provided all conditions in section 8 are satisfied. This right is not absolute; it is conditional on the cardholder holding a qualifying corporate card statement, meeting the corporate policy requirements of section 13, and ensuring the acquisition is not one with an estimated GST amount. The right also extends to reimbursement scenarios under section 14, where the cardholder is taken to meet the statement-holding requirement if they have a statement covering the reimbursed expense.

Cardholder duties:

1. Hold a compliant statement: At the time the GST return is given to the Commissioner, the cardholder must hold a corporate card statement that meets the section 9 information requirements and records the transaction (section 8(1)(a)).

2. Maintain two corporate policies: Section 13 requires the cardholder to have in place:

   • An ‘effectively regulated corporate policy’ (including retention of documentary evidence) for determining the extent of creditable purpose for acquisitions made on the corporate card that are wholly or partly of a private or domestic nature. This addresses mixed-use expenses (e.g., a card used for both business and personal travel). The policy must be effectively regulated, meaning it must be enforced and audited.
   • An ‘effectively regulated corporate policy’ to ensure that the tax invoice and the corporate card statement are not incorrectly used to claim input tax credits more than once for a creditable acquisition. This prevents double dipping by, for example, claiming an ITC based on the corporate card statement and also on a separate tax invoice for the same purchase.

3. Exclude estimated GST amounts: The cardholder cannot rely on the waiver for any acquisition where the corporate card statement includes an ‘estimated GST amount’ calculated under subsection 11(b) (section 8(1)(c)). In such cases, the cardholder must revert to holding a tax invoice to claim the ITC.

Corporate card provider/acquirer duties:

1. Accuracy: Under section 12, if the provider has reason to consider any information in section 9(d) or an estimated GST amount is not accurate, the provider must not include that information on the statement. This is a proactive duty to exclude known incorrect data.

2. Method for obtaining data: The provider must have in place an accurate method of obtaining or calculating the transaction information in section 9(d) (section 8(2)(b)).

3. Signed statement retention: If the provider chooses to use the signed statement method to calculate GST payable, they must retain the signed statement for at least five years after the supplier ceases their association with the provider (section 10(2)).

4. Option to use signed statement method: The provider can choose this method to satisfy paragraph 8(2)(b) (section 8(2)(c)), but it is not mandatory.

Supplier duties (if they provide a signed statement):

1. Provide a signed statement containing accurate information about their ABN, branch registration number, and the type of supplies made (section 10(1)).

2. Undertake to notify the corporate card provider/acquirer if they cease to be GST-registered or if they cease to make only taxable supplies where GST is 1/11th of the price (section 10(1)(d)). This is an ongoing duty that carries practical risk if overlooked.

Reimbursement rights (section 14): Where the cardholder has a creditable acquisition because of section 111-5 of the GST Act (i.e., reimbursement of an employee or agent), they are taken to meet the statement-holding requirement if they hold a corporate card statement that includes the section 9 details for the expense being reimbursed. The reference to ‘creditable acquisition’ in section 9 is read as a reference to the expense being reimbursed. This extends the waiver to the reimbursement context without imposing additional documentary burdens on the employee.

The determination itself does not create new penalty provisions or enforcement mechanisms distinct from those in the GST Act. Instead, it conditions the availability of a compliance concession; failure to meet the conditions means the cardholder loses the right to rely on the waiver, which in turn may expose the cardholder to GST shortfall penalties and general interest charges under the Taxation Administration Act 1953 (TAA) if ITCs are improperly claimed without a valid tax invoice.

The key enforcement risk is that the Commissioner of Taxation will, during an audit, test whether the cardholder held a compliant corporate card statement at the relevant time, whether the corporate policies were effectively regulated, and whether any transaction with an estimated GST amount was improperly included in the waiver. If the cardholder cannot produce a compliant statement or demonstrate effective corporate policies, the ITC claim may be denied, and the taxpayer may face:

• A shortfall amount equal to the ITC wrongly claimed, plus interest.
• Administrative penalties under Division 284 of Schedule 1 to the TAA for making a false or misleading statement, which can be up to 75% of the shortfall amount if the taxpayer was reckless or intentional.
• Potential penalties for the corporate card provider if it knowingly includes inaccurate information on a statement, though the instrument places the primary compliance burden on the cardholder.

For the corporate card provider, failure to comply with the accuracy requirement in section 12 (i.e., including information it has reason to believe is inaccurate) does not carry a direct penalty under this determination, but it could be considered in determining whether the cardholder’s reliance on the statement was reasonable. The provider may also face reputational risk and contractual liability to the cardholder.

The signed statement retention requirement (five years after cessation of association) is a record-keeping obligation. Failure to retain the signed statement could mean the provider cannot later demonstrate that it used an accurate method, which may undermine the cardholder’s ability to rely on the waiver for transactions from that supplier.

Enforcement in practice depends on ATO risk assessments. Large businesses with high-volume corporate card usage are more likely to be reviewed for the adequacy of their corporate policies. The ‘effectively regulated corporate policy’ requirement is a qualitative standard; the ATO may interpret it to mean that the policy is documented, communicated, and subject to regular review or audit. A paper policy that is not enforced may not satisfy the condition.

There is no separate penalty under this instrument for an individual employee misusing a corporate card; that is a matter of employment law and the cardholder’s internal policy.

Overall, the enforcement architecture is indirect: the instrument creates conditions precedent to a concession; non-compliance removes the concession and triggers ordinary GST law penalties. The practical penalty for non-compliance is the loss of the ITC plus interest and potentially penalties for understatement.

GST Act: The determination is made under the GST Act, specifically under the power to waive the tax invoice requirement in subsection 29-10(3). It does not alter the substantive entitlement to input tax credits; a creditable acquisition must still satisfy the usual requirements (sections 11-1 to 11-30 of the GST Act). The waiver only affects the documentary evidence needed at the time of attribution. Section 111-5 (reimbursement) is specifically referenced in section 14 of the determination, extending the waiver to acquisitions arising from reimbursements. The determination also interacts with the attribution rules in Division 29; by allowing attribution without a tax invoice, it effectively accelerates the timing of ITC claims for cardholders who use this method.

Taxation Administration Act 1953: The determination interacts with the penalty and interest provisions of the TAA. As noted, incorrect reliance on the waiver may lead to shortfall penalties and general interest charge (GIC) under Part IIAA or Part 2-25 of Schedule 1. The determination does not override the requirement for a taxpayer to take reasonable care; relying on a corporate card statement that contains obvious inaccuracies would not constitute reasonable care.

A New Tax System (Goods and Services Tax) Regulations 2019: The regulations contain general provisions about tax invoices (e.g., Reg 29-10.01). The determination operates as an alternative to the standard tax invoice rules. It does not repeal or amend the regulations.

Commonwealth Fraud Control Framework: Cardholders that are Commonwealth entities may also need to comply with the Public Governance, Performance and Accountability Act 2013 (PGPA Act) and the Commonwealth Fraud Control Framework. The ‘effectively regulated corporate policy’ requirement mirrors the internal control standards expected under PGPA, but the determination does not incorporate those laws by reference.

State and territory payroll tax and other taxes: The determination is specific to GST. It does not affect payroll tax, fringe benefits tax (FBT), or income tax. However, corporate card statements may also be used for FBT record-keeping (e.g., for expense payment fringe benefits), but the determination does not waive any requirements under the Fringe Benefits Tax Assessment Act 1986.

Privacy Act 1988: Corporate card statements contain personal information (e.g., names of employees or departments). The collection and retention of such data by cardholders must comply with the Privacy Act 1988 (including the Australian Privacy Principles). The determination does not provide any exemption from privacy obligations.

Contracts and commercial arrangements: The relationship between cardholder, corporate card provider, and acquirer is primarily contractual. The determination imposes statutory conditions on the use of statements for GST purposes, but does not override contractual terms regarding statement accuracy, liability, or dispute resolution.

Previous determination: This instrument repeals and replaces the earlier Legislative Instrument (F2020L00110). It is substantially similar; the key change is the commencement and application dates, likely to ensure continuity. The interaction with the previous determination is that from 11 February 2020, the old instrument no longer applies, and this one governs waiver for tax periods starting on or after 10 February 2020.

This determination is itself a replacing instrument, not an amendment to an existing one. It is numbered ‘No. 2’ to indicate it supersedes the Goods and Services Tax: Waiver of Tax Invoice Requirement (Corporate Card Statements) Legislative Instrument 2020 (registered on 10 February 2020 as F2020L00110). The earlier determination was made under the same legislative power and had the same substantive content.

The reason for the replacement is not stated in the text, but the commencement date (11 February 2020) and application date (tax periods starting on or after 10 February 2020) suggest that the original determination may have had a limited application period or was made to take effect from a specific date, and this No. 2 determination ensures ongoing effect without a gap. The instrument is taken to have commenced on 11 February 2020, the day after the previous determination was registered. This backdated commencement ensures continuity of the waiver.

No further amendments have been made to this determination since its registration. The instrument contains no sunset clause or review date. However, as a legislative instrument under the Legislation Act 2003, it is subject to periodic review and possible repeal if the Commissioner decides to discontinue the waiver.

The definition of ‘corporate card provider’ lists specific entities by name (e.g., American Express, Cabcharge, Diners Club, MasterCard and Visa issuers, etc.). This list could be amended by a later determination to add or remove providers. There is no mechanism in this instrument for self-amendment; any change would require a new legislative instrument.

The signed statement method and the corporate policy requirements mirror those in the replaced determination, suggesting the ATO considered the framework workable and not in need of structural change. The accuracy requirement in section 12 and the exclusion of estimated GST amounts from the waiver are carried over unchanged.

There is no specific litigation history recorded in the instrument, and as a narrowly scoped legislative instrument made under the GST Act, it has not been the subject of independent judicial consideration. The instrument does not cite any court decisions, and the relief it provides is administrative in nature: it waives a documentary requirement but does not create new rights or obligations that would typically ground litigation.

That said, the instrument could be relevant in disputes about the adequacy of a cardholder’s ITC claims. For example, if the Commissioner disallows an ITC on the basis that the cardholder did not hold a valid tax invoice, the cardholder may argue that the corporate card statement satisfied the waiver conditions. The Administrative Appeals Tribunal (AAT) or Federal Court would then examine whether the cardholder held a compliant statement, maintained effectively regulated policies, and whether the transaction was excluded due to an estimated GST amount. No such reported decisions have yet emerged specifically on this instrument.

Potential areas of dispute include:

• Interpretation of ‘effectively regulated corporate policy’: What level of formality and enforcement is required? Is a written policy that is not consistently applied sufficient?
• Whether a corporate card statement that omits the supplier’s ABN (e.g., for a sole trader who uses a driver ID for taxi travel) still satisfies section 9(d)(iii). Section 9(d)(ii) allows ‘driver ID for a supply of taxi travel’ in lieu of supplier identity, but the ABN requirement is separate.
• The meaning of ‘reason to consider’ in the accuracy requirement (section 12): When does a provider have such a reason? If the provider receives a system-generated flag, must it exclude that data even if it is later verified as correct?
• The effect of the cardholder’s failure to maintain policies: Does it retroactively disqualify the waiver for all transactions in the period, or only those where the policy was not followed? The instrument speaks of having the policy in place ‘at the time the cardholder gives its GST return’, suggesting a point-in-time requirement.
• Reimbursement scenarios under section 14: If the employee incurred an expense on a personal card and is reimbursed, the corporate card statement would not include that transaction. Section 14 only applies where the expense is on a corporate card and the reimbursement is covered by section 111-5. The boundary cases could generate disputes.

Without case law, these remain open questions. The lack of litigation may reflect the instrument’s clear drafting and the fact that compliance burdens are high enough that most cardholders prefer to keep full tax invoices for high-value items anyway, or that the ATO has not aggressively audited this area.

1. Estimated GST amounts defeat the waiver: The most significant trap is section 8(1)(c): if the corporate card statement includes an ‘estimated GST amount’ calculated under subsection 11(b) for any transaction, the cardholder cannot rely on the waiver for that particular creditable acquisition. The cardholder must then obtain a standard tax invoice to claim the ITC. Many cardholders may not carefully read the statement and may assume all transactions are covered. The provider must flag estimated amounts, but if the flag is missed, the cardholder risks a disallowed claim.

2. The policy requirement is not just a writing exercise: Section 13 requires an ‘effectively regulated corporate policy’ for two purposes: determining creditable purpose (mixed private/business use) and preventing double claims. The ATO will likely expect evidence that the policy is documented, communicated, monitored, and enforced. A policy that exists only on paper or is rarely audited may not satisfy the standard. This imposes a recurrent cost on the cardholder.

3. No relief for non-compliant supplier data: If the corporate card statement lacks the supplier’s ABN or a brief description, or if the GST payable is not shown (and instead an estimated amount is shown), the cardholder must revert to holding a tax invoice. The cardholder cannot simply ‘fix’ the statement; there is no mechanism to supplement missing data.

4. Five-year retention for signed statements: Corporate card providers that use the signed statement method must retain each signed statement for at least five years after the supplier ceases association. This is a long retention period. If the provider loses the document or the supplier goes out of business, the provider may be unable to demonstrate that it had an accurate method, potentially undermining the cardholder’s reliance.

5. The signed statement undertaking is ongoing: Suppliers who provide a signed statement must notify the provider if they cease GST registration or if their supply type changes. If the supplier forgets, the provider may continue to calculate GST based on outdated information, leading to inaccurate statement data. The cardholder may then be claiming ITCs based on incorrect GST amounts, which could lead to a shortfall.

6. Fuel cards and vehicle identifiers: For fuel cards, the statement must include the ‘vehicle identifier’ instead of the name of the person/department. This is a specific requirement that may not be standard on all fuel card statements. If the vehicle identifier is omitted or is not cross-referenced to the business use, the cardholder may struggle to demonstrate the creditable purpose.

7. Double claim risk: Section 13(b) requires a policy to prevent double claims - e.g., using both the corporate card statement and a separate tax invoice for the same transaction. If an employee submits a receipt for reimbursement and the accounts department processes it without realising it was already on the corporate card statement, the cardholder could claim the ITC twice. The policy must detect and prevent this.

8. Reimbursement scope is limited: Section 14 only applies where the cardholder has a creditable acquisition because of section 111-5. That section deals with reimbursements to employees or agents for expenses they incur in the course of their duties. It does not cover reimbursements to third-party contractors or non-employees unless they fall within the definition of ‘agent’. Careful analysis is needed to ensure section 111-5 applies.

9. The definition of ‘cardholder’ is entity-level: The cardholder is the entity that participates in the arrangement, not the individual user. If a subsidiary uses a parent’s corporate card, the parent is the cardholder. The parent must ensure the subsidiary’s transactions are captured on the corporate card statement and that its corporate policy covers those users. The parent may be liable for ITC claims on those transactions.

10. No waiver for failure to hold statement at time of return: Section 8(1)(a) requires the cardholder to hold the statement at the time it gives its GST return to the Commissioner. If the statement is not yet issued (e.g., periodic statements come out after the return is due), the cardholder cannot rely on this waiver. Many cardholders may need to adjust their BAS lodgement timing or obtain interim statements.

For cardholders (entity using corporate cards):

1. Verify the corporate card provider is covered: Confirm that the issuer of your corporate cards is listed in the definition of ‘corporate card provider’ (section 5) or is an entity authorised by a listed provider. If not, the waiver does not apply, and you must hold tax invoices.

2. Obtain and review corporate card statements: Ensure that each statement you receive contains all the information required by section 9: identity/ABN of your entity, name of person/department or vehicle identifier, transaction date, supplier identity/ABN/branch number, description, GST payable, and total amount. If any of this information is missing or inaccurate, you cannot rely on the statement for that transaction. Flag transactions marked as ‘estimated GST amount’ and exclude them from your waiver claim.

3. Implement two effectively regulated corporate policies:

   • Policy on creditable purpose (section 13(a)): Develop a written policy that prescribes how to determine the extent to which corporate card acquisitions are for a creditable purpose (business use) versus private or domestic use. Include retention of documentary evidence (e.g., logbooks, trip records, expense categories). Ensure the policy is communicated to all card users, enforced, and subject to periodic review or audit. Keep records of policy adherence.
   • Policy to prevent double claims (section 13(b)): Implement procedures to ensure that the same acquisition is not claimed both via the corporate card statement and via a separate tax invoice or reimbursement claim. This may involve centralised processing of credit card transactions, flagging reimbursed expenses against card statements, and training staff on the rule.

4. Hold the statement at time of BAS lodgment: Do not lodge your GST return (or BAS) until you have the relevant corporate card statement in hand. If your statements are issued monthly and your BAS is quarterly, you may need to obtain interim statements or adjust reporting cycles.

5. Keep a record of compliant statements: Maintain an archive of the corporate card statements you rely on for ITC claims. This is essential for audit defence. The GST Act generally requires records to be retained for five years. Ensure statements are legible and in a format that can be provided to the ATO if requested.

6. Handle estimated GST amounts separately: If any acquisition on the statement has an estimated GST amount, you must obtain a standard tax invoice for that acquisition before claiming the ITC. Do not include it in the waiver claim.

7. Train staff and card users: Educate employees on the importance of accurate use of corporate cards, especially for mixed-use expenses. Encourage them to retain receipts for items that may be private/domestic to assist in determining creditable purpose.

For corporate card providers and acquirers:

1. Establish an accurate method (section 8(2)(b)): Develop a system to obtain or calculate the transaction information required by section 9(d) - supplier identity, ABN, description, GST payable, and total amount. This may involve direct feeds from merchant acquirers or from signed statements from suppliers.

2. Accuracy duty (section 12): Implement checks to identify and exclude information that you have reason to believe is inaccurate. This could include merchant category code mismatches, missing ABNs, or flagged transactions where the supplier type is uncertain.

3. Signed statement method (optional) (sections 10-11): If you choose to use this method, obtain a signed statement from each supplier that contains their ABN, branch registration number, the type of supplies, and the undertaking to notify of changes. Retain the signed statement for at least five years after the supplier ceases their association with you. Ensure that the undertaking is actively monitored so that you are notified of changes to the supplier’s GST status.

4. Clearly identify estimated GST amounts: If you calculate an estimated GST amount under section 11(b), mark it prominently on the corporate card statement as an estimate that must be verified. Include advice to the cardholder to obtain a tax invoice before claiming the ITC.

5. Maintain data integrity: Regularly review the data you include on statements for consistency and accuracy. If you become aware of a systemic error, correct it promptly and notify affected cardholders.

For suppliers that provide a signed statement:

1. Complete the signed statement accurately, specifying whether you make only taxable supplies (and if GST is 1/11th of price) or if you are a mixed transaction supplier.

2. Monitor your GST registration status and the nature of your supplies. Notify each corporate card provider/acquirer promptly if you cease to be registered for GST, or if the type of supplies you make changes (e.g., you start making input taxed supplies).

3. Retain a copy of the signed statement for your records, noting the undertaking to notify. Set a reminder to review your status annually.

General best practice:

• Perform a gap analysis: Compare your current corporate card statement against the information requirements in section 9. If your statement lacks any field (e.g., supplier ABN, GST payable), work with your provider to have it added or supplement with other records.
• Audit your systems: Ensure that the corporate card provider is transmitting the required data. Many cardnetworks now include GST amounts and ABNs, but it is not universal.
• Check for transitional issues: This determination applies to tax periods starting on or after 10 February 2020. If you have earlier periods, the previous determination may apply; ensure you have the correct version for the period in question.
• Seek professional advice: The interpretation of ‘effectively regulated corporate policy’ may vary. If you are a large business with complex multi-entity structures, consider obtaining a private ruling from the ATO on the adequacy of your policies.