EV 1051932942270currentnon-binding advice

GST and financial supplies

Non-binding edited private advice. This is an edited version of private advice the ATO gave to a specific taxpayer about their own circumstances. You cannot rely on it — it is not binding and provides no protection for anyone else (see PS LA 2008/4). Use it as a guide to the ATO’s thinking, not as authority.

1

You sought a private ruling on whether you make a supply of an interest in a debt pursuant subsection 40-5.09(1) of the A New Tax System (Goods and Services Tax) Regulations 2019 (GST Regulations), and also whether the nature of the funding you received constitutes a 'recoupment' of research & development expenditure for the purpose of section 355-440 of the Income Tax Assessment Act 1997 (ITAA1997).

2

The Commissioner has provided answers to the issues you sought clarification on. Facts and circumstances You are a party to a funding arrangement.