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For an Australian business buying services from an overseas supplier that is not registered for Australian GST, keep the supplier’s invoice or equivalent payment request, the contract or order, payment evidence, a description of the service and its business use, and a workpaper showing how you assessed reverse-charge GST and any apportionment. There is no single ATO-prescribed document bundle for every purchase. A supplier tax invoice is generally not required for a reverse-charged taxable supply, but you still need records that explain the transaction and support your GST treatment and any input tax credit.
What to save for each imported service
Build a file that lets someone who was not involved in the purchase understand what the business bought, how it was used, and why the business reached its GST conclusion. The documents do not all need to be in one system, but they should be easy to retrieve and link to the transaction in your accounts.
| Record | What it helps establish |
|---|---|
| Supplier invoice, statement, payment request, or equivalent record | The supplier, date, amount, currency, and description of the service, to the extent the record provides those details. |
| Contract, order, subscription terms, statement of work, or relevant correspondence | What was agreed, the service’s scope, and any terms needed to understand what was supplied. |
| Payment evidence | That the business paid the supplier and the amount paid. Keep a currency-conversion record if one was used in the accounting or GST calculation. |
| Internal service and business-use note | How the service relates to the Australian business and whether it was used wholly or partly for business purposes. |
| GST workpaper | The facts considered, whether Division 84 was assessed, the conclusion, any calculation, and the basis for an apportionment. |
| Records supporting the GST return treatment and any input tax credit | How the transaction was reported and the evidence supporting any credit claimed. |
This is a practical evidence set based on Australian Taxation Office record-keeping guidance, not an exhaustive statutory checklist. The records required in a particular case depend on the transaction and the GST treatment claimed.
Why the supplier may not give you an Australian tax invoice
An overseas supplier that is not registered for Australian GST may provide a commercial invoice or payment request rather than an Australian GST tax invoice. Do not treat the absence of an Australian tax invoice as proof that the purchase has no GST consequences, or as a reason to leave the transaction undocumented.
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For a taxable supply on which GST is reverse charged, the ATO says the supplier is not required to issue a tax invoice. The recipient should still retain evidence that explains what was acquired and supports the way the transaction was treated, including any input tax credit claimed. The supplier’s invoice or equivalent is useful evidence, but the contract, payment record, business-use information, and GST workpaper may also be important to understanding the transaction.
Keep the records the supplier actually provides. If there is no conventional invoice, use the available payment request, account statement, order confirmation, subscription record, or correspondence together with the payment evidence. Record what information is missing and retain other documents that clarify the service and amount. This is a practical way to preserve the transaction trail; it does not turn a commercial document into an Australian tax invoice.
Check whether Division 84 applies before deciding how to report the purchase
The supplier’s lack of Australian GST registration does not, by itself, decide whether the Australian recipient has a GST liability. Division 84 can make the recipient liable for GST on certain supplies from offshore suppliers when its requirements are met. The ATO’s GSTR 2019/1 explains the relevant connection and purpose requirements. The character and use of the service matter, and the rules do not mean every service bought from overseas is reverse charged.
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Assess the facts of the particular acquisition rather than relying only on the supplier’s location, invoice format, or registration status. Among the questions to document are:
- What service was actually supplied, and what do the contract, order, or correspondence say about its scope?
- What connection does the supply have to Australia for GST purposes?
- Was the recipient registered or required to be registered, and was the service acquired for an Australian enterprise?
- Is the supply GST-free or input taxed, or could another relevant treatment affect the Division 84 assessment?
- Was the service used for taxable, GST-free, input-taxed, or private or domestic purposes?
- If it had mixed use, what part of the use supports the calculation or apportionment applied?
These are assessment questions, not a substitute for applying the legal tests to the facts. The ATO gives an example involving an Australian financial institution that acquires information from a US provider: if the relevant requirements are met, the Australian recipient can be liable for GST. The example illustrates why an offshore supplier’s status alone is not a complete answer.
Make the GST workpaper explain the decision
A useful workpaper is concise but specific enough to show what was considered. It should be prepared or retained with the transaction records, not reconstructed from memory when a return is reviewed. The ATO’s cross-border record guidance discusses keeping records of steps taken to identify cross-border supplies and supplies subject to reverse charge. Its record-keeping ruling, GSTR 2006/4, addresses records of the particulars and basis or method for relevant GST estimates, determinations, and calculations.
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Record the facts relied on
Identify the supplier and transaction, describe the service, and point to the supporting invoice, order, contract, or correspondence. Note the business purpose and use, including any facts relevant to the connection and purpose requirements. A short cross-reference to the source documents is more useful than a bare entry such as “overseas software” or “no GST.”
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State whether the business considered Division 84 and the conclusion reached, with enough explanation to connect the conclusion to the facts. If the business concludes that the rules do not apply, note the reason rather than relying solely on the supplier’s lack of registration or the absence of GST on the invoice. If the reverse charge applies, keep the calculation and the records supporting the GST return treatment.
Document any apportionment
If the service has mixed business and other use, or its use relates to supplies with different GST treatment, retain the method used to apportion it and the facts or records supporting that method. The ATO identifies records of apportionment methods as relevant. A number without an explanation of how it was reached may not show why the return treatment was appropriate.
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Keep evidence of the service’s business use
An invoice may identify a product or subscription without explaining how the Australian business used it. Add an internal note that names the business function, team, project, or activity the service supported. Where use is not obvious from the invoice, the order or correspondence may help clarify what was acquired; the internal note should connect that description to the recipient’s actual use.
For example, if an overseas provider supplies business information, the file can include the purchase record and a note explaining which business activity used the information. The ATO’s financial-institution example shows why it is important to capture the nature and purpose of a service rather than making the GST assessment from a supplier’s country alone. Do not assume that this example determines the treatment of a different service or business.
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ATO record-keeping material describes a five-year minimum for relevant GST records, with retention rules that can extend beyond five years where an assessment review period or a later amendment is relevant. Do not treat five years as an absolute maximum. The applicable period depends on the circumstances, including the transaction or act and any related review or amendment. GSTR 2006/4 discusses record retention and the basis for GST calculations, estimates, determinations, and choices.
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Keep the supporting documents together or cross-reference them to the accounting entry so that the invoice, payment, contract, workpaper, apportionment basis, and return treatment can be located as a set. Apply your organisation’s retention process in a way that accounts for any longer period relevant to the transaction.
A practical review before lodging the GST return
- Match the purchase to its source records. Confirm that the supplier record, order or contract, payment evidence, and accounting entry relate to the same service and amount.
- Describe the acquisition. Make sure the file identifies the service clearly enough to assess its Australian GST treatment, rather than recording only a supplier name or generic category.
- Record the recipient’s business purpose and use. Include any mixed or non-business use that may matter to the GST assessment or an input tax credit.
- Assess Division 84 on the facts. Document the relevant connection and purpose considerations, and whether the supply’s character or GST-free or input-taxed status affects the conclusion.
- Support the calculation and return treatment. Retain the workpaper, any currency conversion used, the apportionment method if applicable, and records supporting the GST return entry or credit claimed.
- Check that the file is retrievable. Link the evidence to the transaction and retain it for the applicable period, which may be longer than five years.
Common record-keeping mistakes
- Stopping at “the supplier is unregistered.” That fact does not settle whether Division 84 applies. Record the assessment of the actual transaction.
- Assuming an overseas invoice must be an Australian tax invoice. A supplier is not required to issue a tax invoice for a reverse-charged taxable supply, but the recipient still needs supporting records.
- Keeping only the invoice. The invoice may not show the service’s contractual scope, actual use, payment, or the reasoning behind the GST treatment.
- Recording an apportionment without its method. Preserve the basis and supporting facts for the calculation, not only the result.
- Applying the same conclusion to every offshore service. Division 84 is fact-dependent; different services and uses can produce different assessments.
- Discarding records automatically after five years. Relevant review-period and amendment rules may require longer retention.
Scope: services are not goods imported through customs
This guidance concerns services supplied from overseas to an Australian business. It is not a guide to goods imported through customs, where different import arrangements and records may be relevant. Nor does it determine the treatment of every imported service. If the service involves financial supplies, mixed use, complex contractual arrangements, or uncertainty about Division 84, obtain advice on the specific facts before finalising the GST treatment.
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