GST Remission for Prescribed Funds: Evidence, Undertakings and Claim Years

Five-page explanatory notes

The notes cover prescribed funds, including VCCs, that meet all qualifying conditions. Recoverable expenses must serve qualifying investment activities; expenses disallowed under regulations 26 and 27 remain excluded. The notes explain documentary concessions and claim-year examples, rather than giving every income-tax incentive condition.

Invoices to the fund and trustee

Normally a valid tax invoice complying with regulation 11 supports the claim. Where addressed to a trustee, the expense must appear in the respective fund’s accounts and be paid from its bank account. Retain a trustee statement or letter identifying the allocated expense and GST and referencing the supplier invoice. The trustee completes Appendix 1. This concession is specifically for prescribed-fund GST remission.

All six umbrella or master-fund conditions

The umbrella/master must be ineligible for GST registration or GST remission; both it and the sub-fund must be unincorporated; and both have the same trustee. Recognise the expense in the sub-fund’s accounts and evidence payments from its bank accounts. Retain an allocation statement/letter with GST and a reference to the supplier’s umbrella invoice. The trustee completes Appendix 1. Do not assume this particular unincorporated-entity concession automatically covers every VCC umbrella.

Invoices to a fund manager

Recognise expenses in the fund’s accounts and retain payments from its bank accounts. A manager statement or letter identifies allocated expenses, GST and the corresponding supplier invoice. The manager completes the relevant undertaking. A manager-addressed invoice alone does not establish all three conditions.

Appendix 1: prevent duplicate claims

Select trustee, umbrella/master, manager or others and identify the name and Entity ID. The trustee undertakes no past or future claim through its GST return or another Statement of Claims in trustee capacity; the umbrella/master undertaking likewise covers its return and other statements; the manager undertakes no claim through its own GST return. Each has authorised signatory, signature, designation/identification number and date. Explain other claims in the provided space.

Appendix 2: preceding-year eligibility

For a December year-end, satisfying YA 2018 on FY ending 31 December 2017 supports claims from the approval date to end-2018; satisfying YA 2019 on FY ending December 2018 supports 2019 claims. Commencement is the later of GST-remission effective date and grant of the specific income-tax concession; remission ends on the final qualifying day.

New funds and a failed first-year spending condition

A fund with no preceding year, or failing that condition in the first year of its income-tax concession, may claim first-year GST if it meets the specific concession by first-year end. If minimum spending prevents first-year qualification but conditions are met by second-year end, only second-year GST becomes claimable, after eligibility is established; first-year GST stays unclaimable. Funds self-assess this further concession without prior IRAS approval.

All four illustrated financial year-ends

The image-only page gives sixteen quarters for each year-end. For 31 March, the four quarters April 2017–March 2018 correspond to YA 2018, then April 2018–March 2019 to YA 2019, April 2019–March 2020 to YA 2020 and April 2020–March 2021 to YA 2021. For 30 June, July 2017–June 2018 uses YA 2018, followed by the next three July–June years using YAs 2019–2021.

For 30 September, October 2017–September 2018 uses YA 2018, then October–September years use YAs 2019–2021 through September 2021. For 31 December, January–December 2017 uses YA 2017, then calendar years 2018, 2019 and 2020 use YAs 2018, 2019 and 2020 respectively. Thus the calendar-year-end table differs from the other three examples; do not shift it one YA.

Appendix 3: both claim registers

For every claim period retain purchase listings with actual invoice date (DD/MM/YYYY, not processing date), invoice number, supplier GST registration number, supplier name, expense description, purchases before GST and GST incurred. Supply them on request. For invoices dated in another accounting period retain a late-claim list with period from/to, purchases before GST, total GST, fixed recovery rate and claimable GST. Aggregate invoices claimed in the same year at the same recovery rate; do not combine differing recovery-rate groups.