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What Reliance can we place on “no supply”?


Reliance Carpet is one of a number of cases where the Courts have not found a “supply”. The decision has application to more than just “security deposits” and has also shown the limits to the “purposive approach” of interpreting the GST legislation.

Author profiles

Brad Miller CTA
Brad is a Partner in EY’S Indirect Tax team in Melbourne, advising on a range of indirect taxes including GST. While Brad assists clients in different industries, he focuses on clients in the financial services sector (including superannuation) by providing clear and concise value propositions to clients on very technical aspects of the GST legislation. Brad also assists clients from an indirect tax perspective on due diligence; structuring for acquisitions; divestment, developing and documenting GST apportionment methodologies; and managing ATO audits and disputes. Brad is an active member of a number of indirect tax committees for different industry associations, regularly advocating on behalf of those associations before both the ATO and Treasury. - Current at 30 September 2015
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James Choi
James is an Associate Partner with EY’s Tax practice, James has extensive experience advising on all indirect tax matters. He resolves GST issues arising in the Government and private sectors with a particular focus on property transactions,mergers and acquisitions, asset finance, cross border arrangements and general business operations. Specialties: Indirect tax, GST, Government, property, mergers and acquisitions, asset finance, cross border arrangements. - Current at 30 September 2019
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