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01 Feb 2019

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.


This issues paper was released for public consultation. Consultation closed on 5 April 2019.

The issues paper resulted in a new item being added to the Public Guidance work programme - see PUB00355: GST - Grouping - How the group rules operate.

About issues papers

Inland Revenue’s Tax Counsel Office (Public Advice and Guidance) develops and publishes public statements interpreting the tax laws.

Where significant uncertainty exists, it helps us to hear from interested parties before we prepare a public statement. This generates discussion so we gain a better understanding of the issues, including practical concerns. An issues paper sets out our initial views on how the relevant tax laws may apply. If it results in the issue of a draft public statement, public consultation will occur in the usual manner.

Given that issues papers produced by the Tax Counsel Office represent our initial views only, taxation officers, taxpayers and practitioners must not rely on them. Only finalised public statements represent authoritative statements by Inland Revenue of its stance on the issues covered. 

Any views presented in an issues paper do not change the Commissioner’s current position or practices.

Find out more about issues papers