Archived issues papers
IRRUIP 13: Consequences of GST group registration
This issues paper examines the consequences of GST group registration. The GST group registration rules allow a group of related entities to be treated as a single entity for GST purposes. Supplies made or received by a group member are treated as made or received by the representative member. Taxable supplies between group members may be ignored. In this way, the Act creates a statutory fiction – something is treated as having been done by one person (the representative member), when in fact it has been done by another (the group member). We understand that views differ about the extent of this statutory fiction. This issue paper sets out two possible interpretive approaches to the GST group registration rules and identifies cases where the GST outcome differs depending on the approach applied. The issues paper seeks feedback on which approach should be preferred.
(PDF | 878KB | 69 pages)