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The Vouchers Problem: and Insoluble Conflict or an Illustration of the Nature of Consideration in the 'Complex Parallel Universe' of GST?


This paper examines the Australian GST treatment of vouchers, focussing on the difficulties that arise in trying to determine the taxable value of supplies made when vouchers are redeemed. It proposes a set of basic GST principles, discusses the way in which Australian GST attempts to embody those principles, and then evaluates the treatment of vouchers by reference to those principles. In the process, it critically examines the Commissioner's draft views on the vouchers regime in Division 100 and proposes an alternative interpretation. Having done so, the paper evaluates both interpretations by reference to one simple and four more complicated voucher transactions, including the supply and redemption of telephone cards, 'free' vouchers, retail loyalty scheme vouchers, and vouchers accepted by a supplier other than the one that issued them. Having concluded that there are insoluble difficulties with the current regime in Division 100, the paper calls for legislative amendment of the GST Act.

Author profile

Prof Rebecca Millar
Rebecca is a Professor at the University of Sydney Law School. Professor Millar is an academic member of the Technical Advisory Group (TAG) advising Working Party 9 of the OECD’s Committee of Fiscal Affairs (CFA) on the development of international guidelines for GST and VAT cross-border services rules. She also works with the IMF and the World Bank, drafting VAT and excise tax laws and providing other technical assistance to developing countries. From 2002 to 2007, she was a member of the Australian Taxation Office GST Rulings Panel (later the Indirect Tax Rulings Panel) and in 2008, she was a member of the expert panel appointed by the Board of Taxation for its Review of the legal framework for the administration of the GST. - Current at 01 October 2009
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