ATO Clarifies GST Rules for Power Industry: BPPAs, Gifted Assets, and Agency Arrangements

• The ATO released updated guidance in December 2025 clarifying GST treatment for Bundled Power Purchase Agreements (BPPAs), gifted assets in connection services, and agency arrangements in the energy sector.
• For BPPAs, the ATO confirms that the supply of the Contract for Difference (CfD) is an input-taxed financial supply, while the supply of green products is a taxable supply.
• GST on green products is attributed upfront when the Off-taker enters into the CfD, requiring the Generator to issue a single tax invoice for all green products expected over the BPPA’s life.
• The ATO advises industry participants to engage further for BPPA variations where consideration for green products differs from the standard arrangement.

Source: minterellison.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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