PGPA Act Determination (Comcover Special Account 2018)

The Determination defines the core legal constructs that govern the account. Key concepts in the instrument are defined in section 4 and used throughout the text.

• The Act: the Public Governance, Performance and Accountability Act 2013 (s 4).
• Comcover: the Commonwealth’s self‑managed insurance fund (s 4).
• Comcover Insurance Policy: a policy of insurance issued by Comcover (s 4).
• Comcover instrument and Comcover account: the prior Financial Management and Accountability Determination 2009/05 , Comcover Special Account Establishment 2009, and the special account established by that instrument (s 4).
• The special account (Comcover Special Account 2018): the account established by this Determination (s 4; s 5).
• General Government Sector entity: a Commonwealth entity, Commonwealth company, or the High Court of Australia that the Australian Bureau of Statistics classifies within the General Government Sector according to the Standard Institutional Sector Classification of Australia (s 4).
• Insured Commonwealth entity: a General Government Sector entity that holds a Comcover Insurance Policy (s 4).
• Opening balance: the amount required to be credited on establishment equal to the amount standing to the credit of the Comcover account immediately before repeal of the Comcover instrument (s 4; s 9).

Operational permitting language is central: sections 7 and 8 are expressed as permissive provisions , "amounts that may be credited" (s 7) and "purposes ... in relation to which amounts may be debited" (s 8) , rather than mandatory prescriptive duties. Section 9 is an exception: it uses mandatory language for the opening balance, stating the amount "is required to be credited" to the special account on establishment (s 9(1)).

The Determination also defines a narrow class of liability called an "uninsured superannuation liability claim" , a claim (in tort or otherwise) against an insured Commonwealth entity relating to eligibility to participate in the superannuation schemes listed (Superannuation Acts of 1922, 1976 and 1990) that accrued before the insured entity began to hold a Comcover Insurance Policy (s 4). Section 8(d) then expressly includes payments in respect of such claims among permitted debits.

Two structural mechanisms are notable:

• Repayment and residual mechanics: the account may be used to repay amounts received from insured Commonwealth entities that remain after making other permitted payments (s 8(f)), and to repay amounts where a court order, Act or other law requires or permits repayment (s 8(g)).
• Reduction of appropriation without payment: the account may be debited "to reduce the balance of the special account (and, therefore, the available appropriation for the special account) without making a real or notional payment" (s 8(h)). The Determination itself explains the direct effect of that mechanism on the available appropriation for the account.

Finally, the Determination contains a temporal transitional device: Part 3 (opening balance and repeal of the prior instrument) is to be repealed seven days after repeal of the Comcover instrument, but the legal effects of Part 3 remain in force after that repeal (s 11(1)-(3)). Several definitions used only for the transitional provisions are also scheduled to be repealed on that date (s 11(2)).

This Determination directly affects a defined set of government actors and private parties in concrete ways.

• The Secretary of the department that administers Comcover: named as the accountable authority responsible for the special account (s 6). That person or office will have responsibility for the account under the Act as referenced by the Determination; the instrument places responsibility, not explicit duties, on that office.
• Comcover as the Commonwealth self‑managed insurance fund: the Determination establishes the special account to support Comcover’s functions (definitions and ss 5, 8(b)).
• Insured Commonwealth entities: defined as General Government Sector entities that hold a Comcover Insurance Policy (s 4). These entities are the primary payees and payors in the Determination’s scheme:
  • They may receive repayments of amounts they previously credited to the account that are residual after permitted payments (s 8(f)).
  • They are subject to coverage by Comcover policies, and the account may be debited to make payments in respect of liability claims against them (s 8(c)) and in respect of uninsured superannuation liability claims under the defined conditions (s 8(d); s 4).
• Claimants against insured Commonwealth entities: persons or parties making liability claims (including tort claims) against insured Commonwealth entities are affected by s 8(c) (payments in respect of liability claims) and by s 8(d) when the claim qualifies as an uninsured superannuation liability claim (s 4).
• Persons who make payments to the account: the account may receive amounts "received from any person for one or more purposes of the special account" (s 7(b)). That phrasing includes premiums, reimbursements, or other receipts from insured entities and third parties, although the Determination does not list particular income streams other than the opening balance (s 7).
• The prior Comcover account and any entities that dealt with it: the Determination repeals the prior instrument and requires the opening balance transfer (ss 9-10). Record-keeping and transition tasks previously handled under the 2009 instrument are addressed by the repeal and opening balance provisions.
• The Australian Bureau of Statistics and classifications: indirectly, because the definition of "General Government Sector entity" depends on ABS classification (s 4). Entities whose classification changes with ABS practice may move into or out of the defined insured Commonwealth entity category.

Actors not explicitly affected: the Determination makes no express references to penalty regimes, private licencing requirements, or third-party regulatory approvals. It also does not create new statutory rights for private claimants beyond allowing debits from the account for certain payments; whether a claimant receives payment still depends on claim circumstances and Comcover practices (s 8(c)-(d)).

The Determination primarily confers powers to receive and expend funds; it contains very limited mandatory duties. The text differentiates between permissions (what may be credited and debited) and requirements.

Mandatory/required actions

• Credit opening balance: the Determination requires that a specific opening balance be credited to the special account on establishment , "the amount in subsection 9(2) ... is required to be credited to the special account on the date of its establishment" (s 9(1)). Subsection 9(2) defines the opening balance as "the amount standing to the credit of the Comcover account immediately prior to the repeal of the Comcover instrument" (s 9(2)). This is explicit and mandatory language.
• Repeal the prior instrument: the Determination expressly repeals the Comcover instrument (s 10).

Permissive powers (rights to credit and debit)

• Credits: amounts "that may be credited" include amounts received in the course of performing functions that relate to the purposes of the special account, and amounts received from any person for one or more purposes of the special account (s 7(a)-(b)). This language authorises receipts into the special account but does not require the account to accept any specific receipt beyond the opening balance.
• Debits: amounts may be debited from the account for the defined purposes in s 8(a)-(h). The listed purposes give the accountable authority the power to make payments for risk management promotion, administration of Comcover functions, liability payments including settlements, uninsured superannuation liability claims, incidental costs including administrative costs, repayments to insured entities for residual amounts, repayments required by law or court order, and the specific mechanism to reduce the account balance without a real or notional payment (s 8).

Accountability and decision‑making locus

• Accountable authority: the Determination designates the Secretary of the department that administers Comcover as the accountable authority responsible for the special account (s 6). The Determination does not set out internal decision rules, delegation arrangements, or processes for how the Secretary should exercise the powers to credit or debit the account. It establishes the locus of responsibility under the Act for the special account.

Temporal requirements and transitional duties

• Part 3 temporary provisions: Part 3 (covering opening balance and repeal of the prior instrument) is itself scheduled to be repealed seven days after repeal of the prior Comcover instrument (s 11(1)), and certain definitions used only for Part 3 will be repealed on that date (s 11(2)). Despite those repeals, s 11(3) preserves the effects of Part 3 after its repeal, which means actions taken under Part 3 (for example the crediting of the opening balance) retain effect even after the textual repeal of that Part.

What the Determination does not do (absence of duties and rights)

• The instrument does not create statutory obligations on insured Commonwealth entities to pay premiums or to act in particular ways. It authorises the account to receive amounts from any person (s 7(b)) but imposes no explicit levy or charge.
• The instrument contains no offence provisions, civil penalty clauses, or enforcement measures. It creates an accounting and governance instrument, not a sanctions regime.
• The Determination does not establish adjudicative or claims‑processing procedures for claimants; it authorises payments in respect of claims (s 8(c)-(d)) but does not prescribe how claims are accepted, assessed, or disputed.

Readers should therefore distinguish between mandatory mechanics (opening balance credit and repeal mechanics) and discretionary permissions (what receipts and payments the accountable authority may accept or make). The accountable authority is placed at the decision node for those discretionary uses (s 6).

The Determination contains no penalty provisions, enforcement mechanisms, or criminal or civil sanctioning regimes. A direct reading of the text shows:

• No offences or civil penalty provisions are created by the Determination. The instrument is framed as a determination about establishment, credits, debits, purposes, and repeal; it does not create enforcement clauses, infringement notices, or pecuniary penalties.
• The Determination authorises financial operations (s 7 and s 8) and identifies an accountable authority (s 6), but it does not specify regulatory oversight procedures, audit powers, or specific compliance mechanisms beyond the account mechanics themselves.
• The only mandatory action the Determination imposes is the crediting of the opening balance from the previous Comcover account on establishment (s 9(1)-(2)) and the repeal of the previous Comcover instrument (s 10). Those required actions are administrative and financial transfer measures rather than sanctions.

Consequences of the absence of explicit penalties

• Any compliance or enforcement oversight that applies to the special account will therefore derive from the Act under which this Determination is made (the Determination itself is made under subsections 78(1) and 78(3) of the Act, s 3). The Determination does not restate or reproduce those Act provisions; it simply operates within that statutory framework. The text does not specify how the Act's wider governance mechanisms (for example, audit, financial reporting and accountability obligations) are to be applied to this account, though by virtue of being a special account established under the Act those wider Act mechanisms would be engaged as a matter of statutory architecture outside the Determination’s text. The Determination itself does not enumerate them.
• Operational enforcement of payments in respect of claims (s 8(c)-(d)) is not described in the Determination; whether a claimant receives payment will depend on the practices and decision‑making of the accountable authority and Comcover administration within the scope of the permitted purposes.

Practical point for implementers: the Determination is an establishing and enabling finance instrument rather than an enforcement statute. Comcover’s own internal procedures, the department’s financial controls and the Act’s broader accountability regime (not reproduced here) will supply the operational compliance and oversight framework that governs actions under the special account.

The Determination cross‑references and operates within a skeletal statutory framework. The instrument explicitly interacts with the Act and the superannuation statutes; the text also creates temporal linkage to the prior Comcover instrument. All interactions described below are grounded in explicit references in the Determination.

Interaction with the Public Governance, Performance and Accountability Act 2013 (the Act)

• The Determination is made under subsections 78(1) and 78(3) of the Act (s 3), and several operative clauses are explicitly framed "for paragraph 78(1)(...)" or "for subsection 78(3)" (see ss 5, 6, 7, 8, 9, 10, 11). The Determination therefore uses the Act’s delegation to establish a special account and to repeal a prior instrument.
• The commencement provision states the whole instrument commences on "the day mentioned in paragraph 79(5)(a) of the Act" (s 2). The Determination does not restate that Act provision; it relies on the Act for its commencement day reference.

Interaction with superannuation legislation

• The Determination explicitly defines "the superannuation legislation" as any or all of the Superannuation Act 1922; Superannuation Act 1976; Superannuation Act 1990 (s 4). It then defines an "uninsured superannuation liability claim" as a specific category of claim that accrued before the insured entity held a Comcover Insurance Policy and relates to eligibility to participate in those superannuation schemes (s 4). Section 8(d) permits payments from the special account in respect of such claims. Therefore the Determination interacts with those superannuation statutes by referencing claims that arise under or in relation to them; however, the Determination does not alter the substantive law of those Acts , it only authorises an account to be debited to make payments in respect of qualifying claims.

Interaction with the prior Comcover instrument

• The Determination expressly repeals the Comcover instrument (Financial Management and Accountability Determination 2009/05) (s 10).
• Section 9 requires transfer of the opening balance equal to the credit standing in the Comcover account immediately prior to repeal (s 9(1)-(2)), effecting an accounting transfer and continuity.
• Part 3 itself is scheduled for repeal seven days after the repeal of the Comcover instrument, with several Part 3‑specific definitions to be repealed on that date (s 11(1)-(2)), while preserving the continuing effect of actions taken under Part 3 (s 11(3)). This creates a short‑term textual interaction that preserves practical effects once the transitional wording is removed.

Interaction with ABS institutional classification practice

• The Determination defines "General Government Sector entity" by reference to ABS classification under the Standard Institutional Sector Classification of Australia (s 4). This references an external administrative classification system; changes to an entity’s classification by the ABS could therefore affect whether the entity qualifies as an "insured Commonwealth entity" for the Determination’s purposes.

Interaction with court orders, Acts or other laws requiring repayment

• Section 8(g) permits debits "to repay an amount where a court order, Act or other law requires or permits the repayment of an amount received." That language expressly envisions and authorises the special account to be used to discharge repayment obligations imposed externally by courts or other laws.

Limitations and non‑interactions evident in the text

• The Determination does not purport to alter substantive liabilities, statutory immunities, tort law, or the substantive operation of the Superannuation Acts; it simply authorises the account to be used to make payments in respect of certain liabilities (ss 8(c)-(d)).
• The Determination does not set standards for claims adjudication, compensation calculation, or dispute resolution; those operational mechanisms are outside the text of this instrument.

In short, the Determination is an accounting instrument that embeds itself in the Act’s delegated powers and references external statutes and administrative classifications for definitional purposes. It authorises financial flows between the Commonwealth’s Comcover function and insured entities, and contemplates interplay with court orders and superannuation legislation in defined circumstances.

The instrument itself records an effective date and a transitional repeal mechanism; it does not record subsequent amendments within its text. What the Determination contains as to history is:

• Date and signatory: the instrument is signed and dated 20 November 2018 by the Minister for Finance and the Public Service (M. H. P. Cormann), which is the administrative provenance and date the Determination was made (top of instrument).
• Commencement: section 2 sets commencement as "the day mentioned in paragraph 79(5)(a) of the Act." The Determination therefore ties its commencement to a provision of the Act rather than fixing a calendar date in the Determination itself (s 2).
• Repeal of prior instrument: section 10 repeals the earlier Comcover instrument (Financial Management and Accountability Determination 2009/05) on the date of effect (s 10). Section 9 requires that the opening balance equal the credit standing of the prior Comcover account immediately prior to that repeal (s 9(1)-(2)).
• Self‑repeal of transitional provisions: Part 3 of this Determination is itself slated for repeal at the end of the seventh day after repeal of the prior Comcover instrument (s 11(1)). On that date several definitions used exclusively for Part 3 are repealed (s 11(2)). Despite those textual repeals, subsection 11(3) preserves the legal effects of Part 3 after repeal.

There is no record within the instrument of any later amendments, schedules, or Ministerial determinations that alter its terms. The Determination therefore presents a one‑time transitional and establishing instrument: it establishes the account, imports the prior account balance, repeals the earlier instrument, and schedules a short textual clean‑up (repeal of Part 3 definitions). Any subsequent modifications or amendments would appear in later instruments or legislative action not contained in this text.

Practically, the Determination’s own repeal scheduling for Part 3 is an internal amendment mechanism: it removes transitional text after a short period while leaving the practical transfers and effects in place. The Determination does not provide for future amendments; amendments would be issued as separate determinations or statutory instruments under the Act.

The Determination contains no judicial decisions, litigation references, or case citations. It does not record any prior or ongoing litigation. The text names no cases, courts or disputes, and does not indicate that it is the subject of any legal proceedings.

Where the Determination contemplates court orders, it does so only in the context of repayment mechanics: subsection 8(g) permits debits to repay an amount "where a court order, Act or other law requires or permits the repayment of an amount received." That is a forward‑looking authorisation to satisfy judicially or statutorily imposed repayment obligations; the Determination itself does not discuss litigation outcomes or processes.

Therefore, based solely on the instrument, there is no litigation history to report. Any litigation arising from claims against insured Commonwealth entities, disputes over withdrawals from the special account, or challenges to the repeal of the prior Comcover instrument would have to be identified from court records or other materials external to this Determination.

The Determination contains several provisions that can generate practical or interpretative pitfalls for implementers and affected parties. These are factual mechanisms in the text that have operational consequences.

1. Opening balance timing and amount (s 9)

• The Determination requires the opening balance to equal "the amount standing to the credit of the Comcover account immediately prior to the repeal of the Comcover instrument" (s 9(2)). The precise quantum therefore depends on the state of accounts at the instant before repeal. Any delays, misstatements, or accounting timing issues with the Comcover account immediately before repeal will determine what is transferred. Because the Determination fixes the opening balance to that immediate pre‑repeal balance, timing and reconciliations matter.

2. Short‑lived transitional definitions (s 11)

• Part 3 and three definitions are scheduled for repeal seven days after repeal of the Comcover instrument (s 11(1)-(2)). However, subsection 11(3) preserves the effects of Part 3 after repeal. Implementers must therefore ensure they complete any administrative steps tied to the definitions in that seven‑day window, while recognising that the substantive effects (for example, the crediting of the opening balance) remain in force despite the textual repeal. Failure to act within the transitional window could create administrative confusion even if legal effect persists.

3. "Insured Commonwealth entity" depends on ABS classification (s 4)

• The Determination defines "insured Commonwealth entity" as a General Government Sector entity that holds a Comcover Insurance Policy (s 4). The Determination adopts the ABS classification to determine whether an entity is a General Government Sector entity. Changes in classification by the ABS could therefore alter which entities qualify as insured Commonwealth entities. This creates potential ambiguity for entities near boundaries of classification, and for entities whose ABS classification changes over time.

4. Narrow definition of uninsured superannuation liability claim (s 4; s 8(d))

• Payments in respect of "uninsured superannuation liability claims" are permitted, but only where the claim:
  • is against an insured Commonwealth entity;
  • relates to eligibility to participate in the specified superannuation schemes (Superannuation Acts of 1922, 1976, 1990); and
  • accrued before the insured Commonwealth entity began to hold a Comcover Insurance Policy (s 4).
• This temporal accrual condition (the claim must have accrued before the entity held a policy) is a strict filter; claims arising after policy commencement are excluded from the definition and thus from s 8(d). Implementers and claimants must therefore track policy start dates carefully.

5. Reduction of balance without a real or notional payment (s 8(h))

• Section 8(h) permits debiting the account "to reduce the balance of the special account (and, therefore, the available appropriation for the special account) without making a real or notional payment." The Determination itself states the immediate fiscal effect: the available appropriation for the special account will be reduced. Implementers must understand that this is an authorised accounting technique to lower the appropriation; the Determination does not explain the administrative or reporting processes needed to record such a reduction, nor any policy reasons for its use. The mechanism could affect budget reporting and year‑end balances.

6. No procedural guidance for claims (ss 7-8)

• Sections 7 and 8 do not provide operational procedures for how Comcover will accept, assess, or pay claims. They authorise payments for particular purposes but leave claim handling processes to the accountable authority. Entities and claimants therefore cannot rely on the Determination alone to ascertain claims timelines, dispute processes, or documentation requirements.

7. Accountable authority named, but duties unspecified (s 6)

• The Secretary is designated as the accountable authority (s 6). The Determination does not specify how decisions are to be taken, delegated, or reviewed within the department. Implementers must therefore consult departmental governance instruments and the Act for operational accountability processes outside the Determination.

8. Commencement tied to a provision of the Act (s 2)

• The Determination commences "the day mentioned in paragraph 79(5)(a) of the Act" (s 2). Because the Determination does not fix a calendar date within its own text, implementers must check that Act provision to determine precise commencement timing. The Determination’s header bears the date 20 November 2018, but the text ties legal commencement to the Act’s paragraph rather than stating the date explicitly.

9. Scope limitation to General Government Sector entities (s 4)

• The range of "insured Commonwealth entity" is limited to General Government Sector entities that hold policies. Commonwealth entities not classified within the GGS by the ABS do not qualify as insured Commonwealth entities for the Determination’s purposes, meaning that Comcover coverage, and the account’s payment powers in respect of claims against those entities, may not apply under this Determination.

10. Nature of the instrument , accounting not adjudicative

• The Determination is an enabling accounting instrument. It does not create entitlements or adjudicate claims; it authorises the account to be used for defined purposes. Parties seeking substantive rights or remedies will need to look beyond this Determination to Comcover policies, departmental practice, the Act, and substantive law.

These points are all grounded in the text of the Determination and should be considered by finance, legal and compliance teams during implementation and by claimants and insured entities when assessing recoveries or liabilities.

Compliance under this Determination is primarily an administrative and accounting exercise for the department administering Comcover and the Secretary designated as the accountable authority. The Determination establishes permitted actions and a mandatory opening balance transfer. The following practical compliance steps are tied directly to the text.

1. Confirm commencement date

• Check paragraph 79(5)(a) of the Act to determine the precise day on which the Determination takes effect (s 2). Do not rely solely on the instrument’s signing date; the commencement clause ties legal effect to the Act.

2. Credit the opening balance

• As required by subsection 9(1), ensure the opening balance defined in subsection 9(2) is credited to the special account on its establishment (s 9(1)-(2)). The opening balance equals the amount standing to the credit of the Comcover account immediately prior to repeal of the Comcover instrument. Practical steps:
  • Reconcile the Comcover account balance immediately prior to repeal.
  • Prepare and execute the journal entry or transfer to the new Comcover Special Account 2018 on the commencement date.
  • Retain audit trails showing the pre‑repeal balance, the transfer instruction, and the credited entry.

3. Repeal and transitional actions

• Give effect to the repeal of the prior Comcover instrument per s 10. After the repeal, note that Part 3 will be repealed at the end of the seventh day after repeal of the Comcover instrument (s 11(1)). Actions:
  • Complete any administrative tasks tied to the definitions in Part 3 within the seven‑day window referenced in s 11.
  • Record that despite textual repeal of Part 3, subsection 11(3) preserves the effects of Part 3; ensure documentation reflects that the opening balance transfer and repeal actions remain in force.

4. Establish receipts and payment processes consistent with s 7 and s 8

• Receipts: ensure systems record amounts received "in the course of the performance of functions that relate to one or more purposes of the special account" and amounts received from any person for the account’s purposes (s 7(a)-(b)). Practical actions:
  • Map possible revenue streams (premiums, recoveries, reimbursements) to the account.
  • Implement ledger and bank arrangements so such receipts can be credited to the special account.
• Payments: authorise debits only for the purposes listed in s 8(a)-(h). Practical steps:
  • Draft internal financial delegations that reflect the accountable authority’s discretion to debit the account for the specified purposes, including settlement payments (s 8(c)), uninsured superannuation liability claims (s 8(d)), incidental administrative costs (s 8(e)), repayments to insured entities (s 8(f)), and repayments required by law or court order (s 8(g)).
  • Document policy rationale and approval flows for using s 8(h) to reduce the account balance without a real or notional payment, including budget and appropriation reporting implications.

5. Track and classify insured entities

• Maintain a register of insured Commonwealth entities consistent with the Determination’s definition, recognising the ABS classification component (s 4). Practicalities:
  • Record each entity’s GGS status per the ABS, policy start dates for Comcover Insurance Policies, and whether any claims predate policy commencement (relevant to uninsured superannuation liability claims, s 4).
  • For insured entities, maintain records of amounts credited to the account on their behalf so repayment under s 8(f) can be calculated.

6. Claims handling and documentation

• The Determination authorises payments for liability claims and uninsured superannuation liability claims (s 8(c)-(d)). Although the Determination does not set claims procedures, compliance requires:
  • Implement or document internal claims assessment procedures that record decision points, legal advice, settlement authority, and payment approvals consistent with the permissible purposes in s 8.
  • Maintain contemporaneous records for any payments made from the account: legal basis for payment, authority exercise, claimant details, and account debits.

7. Repayments and court-ordered payments

• When a court order, Act or other law requires or permits repayment of an amount received, ensure a mechanism exists to debit the special account to satisfy that obligation under s 8(g). Compliance steps:
  • Monitor for judicial orders and statutory obligations requiring repayment.
  • Ensure appropriate legal and financial sign‑offs are obtained before debiting the account.

8. Budget and appropriation reporting for s 8(h)

• If the accountable authority intends to use s 8(h) to reduce the balance without a real or notional payment, implement internal approval and reporting controls to record the appropriation reduction and communicate the effect to budget/reporting units. Steps:
  • Prepare briefings explaining the rationale and financial reporting consequences.
  • Record the debit and the reason in financial statements and appropriation reporting.

9. Audit and records retention

• Because the Determination is an accounting instrument that reallocates funds and sets permitted uses, maintain complete records of:
  • The opening balance reconciliation and credit (s 9).
  • All credits and debits to the special account, mapped to the purposes in s 8 and the authority for each transaction.
  • Decisions and delegations made by the accountable authority (s 6).
• Even though the Determination does not specify audit procedures, standard financial governance practice requires documentation sufficient for external audit.

10. Liaison with ABS and classification bodies

• Because "General Government Sector entity" depends on ABS classification (s 4), build liaison processes with accounting and statistics teams to track classification changes that might affect insured entity status.

11. Legal review and policy alignment

• Ensure legal advice is obtained where payments are complex, where claims involve superannuation law questions (s 4; s 8(d)), or where repayment obligations stem from litigation or legislation (s 8(g)).

Checklist summary

• Confirm commencement (s 2).
• Reconcile and credit opening balance (s 9).
• Record repeal of prior instrument (s 10).
• Implement receipts and payment controls consistent with s 7 and s 8.
• Maintain insured entity register and policy start dates (s 4).
• Establish claims process, documentation and approvals.
• Implement appropriation reporting controls for s 8(h).
• Preserve records for audit and future review.

Following these steps will align departmental processes with the Determination’s textual requirements and the permitted accounting operations it authorises.