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Treatment of input tax attributable to exempt supplies as being attributable to taxable supplies

Goods and Services Tax (General) Regulations

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Subject to regulations 34, 35 and 46A, there shall be treated as attributable to taxable supplies any exempt input tax attributable to supplies of any of the following descriptions:(a)the deposit of money;(b)the exchange of currency (whether effected by the exchange of currency, bank notes or coin, by crediting or debiting accounts, or otherwise) other than the supply of a note or a coin as a collector’s item, investment article or item of numismatic interest;(c)the issue, allotment or transfer of ownership of a debt security by the person who makes the first issue of such security;(d)the issue, allotment or transfer of ownership of an equity security by the person who makes the first issue of such security;(e)the provision by a taxable person of any loan, advance or credit to his employee;(f)the assignment of a trade receivable;(g)the issue of a unit under any unit trust or business trust;(h)the hedging of any interest rate risk that arises or is likely to arise from —(i)the making of any supply specified in paragraph (a) or (c); or(ii)any loan obtained by a taxable person in the making of any supply specified in section 20(2) of the Act;(ha)the hedging of any currency risk that arises or is likely to arise from —(i)the making of any supply specified in paragraph (a), (c), (d) or (g) or section 20(2) of the Act; or(ii)any loan obtained by a taxable person in the making of any supply specified in section 20(2) of the Act;(hb)the hedging of any utility price risk, freight price risk or commodity price risk that arises or is likely to arise from the making of any supply specified in section 20(2) of the Act;(i)the receipt of interest on a bond by a bondholder, arising from the provision of credit by the bondholder to the issuer of the bond (whether or not the bond was originally issued to the bondholder);(j)the receipt of interest in respect of the provision of credit for any trade receivable;(k)the issue or transfer of ownership of Islamic debt securities under an Islamic debt securities arrangement;(l)the provision of financing under an Islamic debt securities arrangement for which the provider of the financing derives an effective return.

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