On 25 September 2013, the ATO issued GST Determination GSTD 2013/3 entitled "Goods and services tax: does item 32 of the table in subregulation 70-5.02(2) of the A New Tax System (Goods and Services Tax) Regulations 1999 apply to some extent in respect of an acquisition for a single fee by a managed investment fund that is a recognised trust scheme from a Responsible Entity?"
It was previously released in draft form as GSTD 2013/D1.
The answer to the question posed is "Yes".
The Determination states that the fund can apply any fair and reasonable methodology to determine the value of the part to which item 32 applies and the value of any other part to which other reduced credit acquisition items apply. A "deductive benchmarking methodology" is considered fair and reasonable where it reasonably approximates the respective values of the parts of the acquisition.