Australia: Ruling on technology-based platform to ascertain fuel use for purposes of fuel tax credit

Australian Taxation Office released Product Ruling 2024/1

Australian Taxation Office released Product Ruling 2024/1

The Australian Taxation Office (ATO) released Product Ruling 2024/1 on a technology-based apportionment, calculation, and reporting platform to ascertain fuel use for the purposes of calculating fuel tax credit entitlement.


Fuel used in heavy vehicles (with a gross vehicle mass of greater than 4.5 tons) for traveling on a public road are entitled to a partial fuel tax credit of 20.8 cents per liter for liquid fuels such as diesel or petrol, while liquid fuel used for all other business purposes (e.g., to power machinery, for traveling off public roads in either heavy or light vehicles) are entitled to a full fuel tax credit of 49.6 cents per liter. If a vehicle travels on both public and non-public roads, or uses fuel to power machinery, it is necessary to apportion the fuel used between these activities and the apportionment methodology used must be “fair and reasonable.” 

The ATO has previously released guidance (Taxpayer Alert TA 2021/3) that outlines its concerns around the use of global positioning system (GPS) technology products for the substantiation of fuel tax credit claims, and the ATO recommends that taxpayers obtain a product ruling for any fuel tax credit technology. Product rulings, if they are used as intended, protect taxpayers from paying more tax, penalties, or interest if the ATO subsequently takes a different view of a taxpayer’s fuel tax credit claim.



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