Prior to 1 Jan 2011
A supply is treated as taking place at the earliest of:
- When payment is received;
- When tax invoice is issued; and
- When services are performed or when goods are removed or made available (the Basic Tax Point).
Based on the general time of supply rules above, a supply is treated as made before GST registration if:
- Payment is received before registration; or
- Services are performed before registration or goods are delivered/ made available before registration.
[Note: The trigger point based on issuance of tax invoice is not relevant as you would not be able to issue a tax invoice before you are registered for GST.]
Administrative concession for continuous supply of services prior to 1 Jan 2011
With regard to a continuous supply of services, the time of supply is based on payment and tax invoice. Therefore, a continuous supply of service is treated as made before GST registration if payment is received before registration. [Note: The trigger point based on issuance of tax invoice is not relevant as you would not be able to issue a tax invoice before you are registered for GST.]
As an administrative concession, IRAS is prepared to treat a continuous supply of services as made before GST registration if the supply of services has been fully performed before registration. This is not withstanding that payment is received after registration.
On and after 1 Jan 2011
With effect from 1 Jan 2011, the general time of supply rules provide that a supply is treated as taking place at the earlier of:
- When payment is received; and
- When invoice is issued.
The Basic Tax Point is no longer applicable for most transactions.
The above rules will determine whether your supply is treated as made by you before you are registered for GST. Hence, if the invoice is issued or payment is received before the date of GST registration, the supply is treated as taking place before registration.
Relief on and after 1 Jan 2011
Notwithstanding the time of supply rules which took effect from 1 Jan 2011, if your services have been fully performed or goods have been delivered/ made available (Basic Tax Point) before you are GST-registered, you will be required, upon request made by your customers who are not entitled to credit for the whole or part of the tax on the supply, to rely on the Basic Tax Point to determine when the supply is made. Hence, no GST is chargeable on your supplies where the Basic Tax Point is triggered before your registration.
To seek relief, your customer and you must complete and sign the “Request for relief of GST on goods or services supplied prior to supplier’s GST registration date” (39KB) form.
For more details, please refer to the e-Tax Guide on GST: Time of Supply Rule (459KB).
Point to note
As you cannot charge GST on supplies made before GST registration, likewise, you cannot claim input tax incurred to make such supplies.