Mutuality and member collections: rotary club receipts were treated as consideration for taxable services under GST.

Amounts collected by a rotary club from its members toward meeting expenses, communication expenses, per capita dues, subscription fees and similar charges were treated as consideration for a supply of services and held liable to GST. The applicant relied on mutuality, contending that member collections pooled for common expenditure could not amount to supply between distinct persons. The Authority rejected that contention on the facts, noting that the receipts were not confined to purely administrative expenses and were also used for club events and other expenditures. It distinguished the cited membership-fee precedent and followed its earlier rulings in similar rotary club matters.

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Issues: Whether the amounts collected by a rotary club from its members towards meeting expenses, communication expenses, per capita dues, subscription fees and similar charges constitute a supply of goods or services liable to GST.

Analysis: The application turned on the scope of supply under GST and the character of the receipts collected from members. The club contended that the collections were pooled for common expenditure and that, applying mutuality, the club and its members could not be treated as separate persons for GST. The Authority, however, noted that the applicant's receipts were not confined to purely administrative expenses and that part of the collections were used for club events and other expenditures. It distinguished the facts from the cited case where the membership fee was held not taxable, and followed its earlier rulings in similar rotary club matters.

Conclusion: The amounts collected by the applicant from its members were held to be consideration for a supply of services and were held liable to GST.

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