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Published on 06 January 2020

Revenue Ruling PTA-021, which deals with the payroll tax exclusion for contractors who ordinarily provide services to the public, has been redrafted following an inter-jurisdictional review and is now open for public comment.

Under the Payroll Tax Act 2007:

  • Certain contractors are deemed to be employees with payments for work under a relevant contract deemed to be wages and  therefore taxable if they also meet the nexus provisions under section 11 of the Act.
  • An exclusion from payroll tax is provided under section 32(2)(b)(iv) of the Act for payments to contractors who ordinarily perform services to the public.  

Following the decision in Nationwide Towing & Transport Pty Ltd v Commissioner of State Revenue in October 2018, Revenue Ruling PTA-021 was withdrawn, with interim advice in respect to applying section 32(2)(b)(iv) published on our website. 

The redrafted revenue ruling - Revenue Ruling PTA-021v2 - is available for public comment until 5pm on Monday 3 February 2020.

We welcome your comments, including suggestions to improve its clarity, via email at

Last modified: 15 September 2020
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