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Inland Revenue

Tax Policy

GST registration requirements in undisclosed agencies

(Clause 152(3))

Summary of proposed amendment

The Goods and Services Tax Act 1985 is to be amended to modify the information requirements relating to transactions that involve land to allow unregistered agents for undisclosed principals to provide the agents’ IRD numbers to suppliers.

Application date

The amendment will apply from 1 April 2011.

Key features

The proposed amendment will modify section 78F which requires a recipient of a supply that involves land to provide certain information to the supplier and allow an unregistered agent for an undisclosed principal to provide the agent’s IRD number to the supplier.


The Taxation (Tax Administration and Remedial Matters) Act 2011 amended the information requirements in section 78F of the GST Act for transactions that involve land to allow an agent for an undisclosed principal to make limited representations to the supplier for the purposes of the GST zero-rating rules. This may be done, however, only if an agent is registered for GST and provides their registration number to the supplier.

In some situations, an agent may be not registered for GST. Law firms, for example, often use “solicitor’s nominee companies” as agents for undisclosed principals. These companies may not have a taxable activity and may not therefore be registered for GST. Requiring these companies to carry on a taxable activity and register for GST so they can act as agents for undisclosed principals would introduce an unnecessary compliance burden.