Tax Updates: 25 August 2025

Welcome to this week’s review of tax issues where Richard comments on what’s been happening in the world of tax over the past week. If you have a question or would like a second opinion on any national or international tax issues, please contact Richard via email at richard@gilshep.co.nz.

QWBA on GST listed services rules

To help you understand what listed services are and how to apply the GST listed services rules if a supply includes listed services with other goods or services, Inland Revenue (IR) has recently released a Questions We’ve Been Asked (QWBA). It’s titled “GST listed services rules: How do the rules apply when there is a supply of listed services and other goods or services?” with the reference QB 25/20.

So what’s the trigger for that grey mass of yours up top there? Well, if the scenario involves transport services (ride-sharing and ride hailing services and delivery services for food and beverages) or accommodation services (excluding exempt accommodation), either of which the underlying supplier (e.g. the driver or accommodation owner) supplies to a recipient in New Zealand (NZ) through an electronic marketplace operator, then you are most likely dealing with listed services, and the associated rules will apply accordingly.

When a supply includes listed services and other goods or services, then you will need to establish whether there is a single supply or multiple supplies—the listed services rules only apply to any supplies of listed services that are separate from other supplies.

So, how do the listed services rules work? Well, they treat the supply as being two supplies: the first supply is from the underlying supplier to the marketplace (which is zero-rated if the underlying supplier is GST-registered), and the second supply is from the marketplace to the recipient. The marketplace must account for GST on the supply it is treated as making to the recipient and pay a flat-rate credit to any underlying suppliers that are not GST-registered.

Assuming that you’ve just managed to get your head around that concept, it becomes slightly more complex if a listing intermediary is also involved, which triggers 3 supplies: underlying supplier to listing intermediary (zero-rated if underlying supplier GST registered), listing intermediary to electronic marketplace (zero-rated), and electronic marketplace to recipient. Once again, the marketplace must account for GST on the supply it is treated as making to the recipient. However, here, it is the listing intermediary who pays a flat-rate credit to any underlying suppliers that are not GST registered.

Circling back around to the whole point of this QWBA, what if there are other goods and services provided at the same time as the listed services? The first thing to establish is whether the other services provided would be considered ‘closely connected services’ (services that are ancillary to the listed service, supplied by the same underlying supplier and advertised, listed or made available through the marketplace to recipients). An example is cleaning services provided by an underlying supplier along with the supply of accommodation services.

Next to decide is whether the recipient has acquired a supply of listed services and a separate supply of the other goods or services, or whether there is a single supply. Once that has been determined, the nature of the relevant supply or supplies needs to be considered (i.e., whether the supply is of listed services or something else). You should ask yourself two questions in this regard:

• What is the true and substantial nature of what is supplied to the recipient for the payment?

• What is the relationship between the different goods or services supplied? Is it reasonable to sever the supply into separate supplies?

If you want more help in answering these questions, then more detailed guidance can be found in the interpretation statement titled GST—Single supply or multiple supplies (IS 18/04).

The QWBA has several examples throughout the commentary to illustrate the application of the rules, a simple flowchart that you can work through to quickly ascertain whether the listed services rules are relevant to your situation, and it’s only a 12-page document, so not overly taxing on one’s schedule.

This article was originally published through the ‘A Week In Review’ newsletter. If you would like to receive Richard’s tax updates every Monday morning, you can subscribe here.