# Tax - From Trader to Investor



## Pommiegranite (9 July 2008)

Hi all, I'd appreciate any input from someone who knows about my situation...thanks:

The last time I sold any stock was around December 2007. Prior to this I had been trading on almost a daily basis.

I now have a portolio which I would like to hold for a couple of more years as an investment. I will not be selling any of this stock for a while, and when I do sell, I wish to pay CGT and not income tax.

So my question is - When will the ATO begin to view me as an investor as opposed to a trader? 

Is one judged on activity in that particular year to decide if that person is a trader or investor - eg. I could be a trader in 07-08, then investor in 08-09 and then back to trader in 09-10.


----------



## storchyman (9 July 2008)

this is my understanding,
if you have held youre position in stock XYZ for min of 12 months, then you pay CGT.

if you have held under 1yr then it is taxable income.

each stock is case by case scenario


----------



## nioka (9 July 2008)

In my experience there is no simple answer. According to my accountant the tax department makes a ruling which has no definite limits and may differ from case to case. I used to be an investor. I did not have to hold each individual stock for more than a year but remained an investor. However when the majority of my stocks were often traded I was deemed to be trading by the tax dept. I have been told that even if some stocks were held for more than one year their profit could still be classed as a trading gain and fully taxed as a trading profit. I was told that the best way to get reclassified was to do no trades for more than one year. That didn't mean that I could not buy or sell, rather it meant how, why and when I sold must be able to be interpreted as investing. I could sell if the funds realised were not reinvested of buy if the funds did not come from trading.

It appears the tax office makes the rules around "loose" regulations. The best thing is to ask the tax office for a ruling but for 07/08 you are probably in a spot.

This info should only be taken as a story of my situation only and is not advice.


----------



## Pommiegranite (9 July 2008)

nioka said:


> In my experience there is no simple answer. According to my accountant the tax department makes a ruling which has no definite limits and may differ from case to case. I used to be an investor. I did not have to hold each individual stock for more than a year but remained an investor. However when the majority of my stocks were often traded I was deemed to be trading by the tax dept. I have been told that even if some stocks were held for more than one year their profit could still be classed as a trading gain and fully taxed as a trading profit. *I was told that the best way to get reclassified was to do no trades for more than one year.* That didn't mean that I could not buy or sell, rather it meant how, why and when I sold must be able to be interpreted as investing. I could sell if the funds realised were not reinvested of buy if the funds did not come from trading.
> 
> It appears the tax office makes the rules around "loose" regulations. The best thing is to ask the tax office for a ruling but for 07/08 you are probably in a spot.
> 
> This info should only be taken as a story of my situation only and is not advice.




Thanks Nioka. What I have bolded is what I plan to do. I may add to my holdings over the whole of this tax year, but certainly won't be selling.


----------



## AlterEgo (9 July 2008)

Can someone explain why the ATO has 2 different classifications? What difference does it make? (besides the 12 month rule for CGT obviously)

I mean, if you never hold stocks for more than 12 months, what difference does it make to the ATO whether you’re classed as a trader or investor?

Eg. Say you are on the 30% tax rate and make a $20K return on shares for the year – all shares held for less than 12 months. If regarded as an investor you’d pay 30% GCT on the $20K, ie. $6K. And if regarded as a trader you’d pay 30% income tax on $20K, ie. $6K.  – same thing! So why would the ATO give a rat’s ---- what classification you’re under (in this case)? This is something that has puzzled me for a long time....


----------



## reece55 (9 July 2008)

AlterEgo said:


> Can someone explain why the ATO has 2 different classifications? What difference does it make? (besides the 12 month rule for CGT obviously)
> 
> I mean, if you never hold stocks for more than 12 months, what difference does it make to the ATO whether you’re classed as a trader or investor?
> 
> Eg. Say you are on the 30% tax rate and make a $20K return on shares for the year – all shares held for less than 12 months. If regarded as an investor you’d pay 30% GCT on the $20K, ie. $6K. And if regarded as a trader you’d pay 30% income tax on $20K, ie. $6K.  – same thing! So why would the ATO give a rat’s ---- what classification you’re under (in this case)? This is something that has puzzled me for a long time....




It makes a lot of difference.....

Primarily, as a trader you hold stocks on a revenue account and as an investor, you hold them on a capital account. Both have advantages and disadvantages. For example, a trader, provided he/she satisfies the non commercial loss provisions, can claim a deduction for a loss. Investors obviously have their losses retained to offset against future capital gains. Traders also can use their portfolio as trading stock.

As someone else has said, there really is no quatatitive levels that triggers the change. It's a qualatative test, so read your ruilings, seek advice and prepare an arguable position paper - FUN!!!.......

Cheers


----------



## AlterEgo (9 July 2008)

reece55 said:


> It makes a lot of difference.....
> 
> Primarily, as a trader you hold stocks on a revenue account and as an investor, you hold them on a capital account. Both have advantages and disadvantages. For example, a trader, provided he/she satisfies the non commercial loss provisions, can claim a deduction for a loss. Investors obviously have their losses retained to offset against future capital gains.




Yes, if you have other income to deduct it from in that year. The same as if it was a capital loss - can only use it in that year if you have other capital gains to deduct it from. I can't see how there is any significant difference. I mean, sure, they may be the odd rare occasion where it may be beneficial to be in one category, or other, to be able to claim the loss in that particular year. But if you don't get to claim it that year, you'll be able to claim it the next, or whenever. You still get to claim it eventually, in either case. Either system may benefit you (marginally) in one year, and perhaps disadvantage you in other years. But over time surely it all evens out, and makes no discernible difference in the long run.



reece55 said:


> Traders also can use their portfolio as trading stock.




And what advantage/disadvantage is that? I can't see how that makes any significant difference either. It may enable you to claim a profit, or loss, on a particular share in one year rather than the next, but really.... it's not going to make any big difference in the long run that I can see. Or am I missing something???



reece55 said:


> As someone else has said, there really is no quatatitive levels that triggers the change. It's a qualatative test, so read your ruilings, seek advice and prepare an arguable position paper - FUN!!!.......




So when does a change get triggered? When you request a change? Or does the ATO make the changes whenever it likes, ie. whenever it suits them for you to be in a different category?


----------



## AlterEgo (9 July 2008)

Maybe is just don't 'get' it. Just answer me this then: if I never hold stocks over 12 months, which category am I better off to be in? And why?


----------



## benn (10 July 2008)

i rang the ato on this last week. i want to defined as a trader so i can offset my heavy losses against my other normal employement income.

i was told to print off some sections from their website ie am i operating a business and the non-commercial loss provisions section.

i was told that it is a self assessment system so if i feel i meet the criteria, i can call myself a trader and do my tax return as a trader. otherwise i can apply for a private ruling but can take a month or two. 

for the non commercial loss provisions to kick in i have to make an income from my business of share trading of $20k. So this is fairly easy to get even tho this $20k is offset by zillions of losses. Anyway this is the way i interpret it.

So ill offset my $150k loss against my $50 employment income, get the tax back and carry forward a loss of $100k for next year to offset against next years employment income.


----------



## korrupt_1 (10 July 2008)

benn said:
			
		

> So ill offset my $150k loss against my $50 employment income, get the tax back and carry forward a loss of $100k for next year to offset against next years employment income.




So have I've understood this correctly?

Traded atleast once a day for the entire financial year.
Nett loss for FY: $100K (with $20K gains and $120K loss)
Regular employment income: $50K
Tax paid: $10K


So by the ruling, I am a trader.

When I submit my tax return, I will get a tax refund of $10k?

Then in the following year (and assuming my income and tax is the same), I will get back another $10k?


----------



## awg (10 July 2008)

there is no way in the wide world that i would self assess big losses as trading loss, then offset my income (unless i was a carefree gambler)

reason: high chance of audit, up till 5 years later. Likely result, disallowance of offset, reassesment including backdated 20%pa interest rate!!!

get a private ruling!!

is reasonably straightforward.

you write up your case using ATO guidline material, print of your of your trade summaries for last 12 months, and submit to them ,takes about 28 days to get written answer.

You could have a problem though.

I never worked at ATO, but Centrelink....same traiing in legislative case decion making etc.

You will NEED to show trading pattern is dominate.

If your evidence shows you are a full time employee, who has some long term investments, and trades even regularly, but not DOMINANTLY, they may say no.

You do mention large amounts though, that would work in your favor, but is only one factor.

that is how we used to work...ie to determine whether someone was in a defacto relationship, each factor was considered, then an on balance decision was reached...decisions are appellable.

this is my opinion only, not advice

tony


----------



## Pommiegranite (10 July 2008)

So are we saying that if in doubt or can't prove, then treat gain/losses as capital, rather than income?


----------



## benn (11 July 2008)

I agree there is a high chance of an audit but i dont see a problem with an audit as it is all legit, and dont see why you should be fearful of an audit and not claim what you;re entitled to by law just because the losses are relatively large.

I am still in two minds about the private ruling. I mentioned it to the ATO over the phone numerous times and was told that if i wanted peace of mind by all means i should apply for one but they are just as comfortable with me self-assessing my individual situation against the criteria of their website information.

I will still be asking my accountant a couple of specific points im unsure of such as...
1. Do i tick Yes or No to the qu about whether i had a capital gains even during the year? I would think this would be No if held on revenue account
2. Do i put dividends received in the dividends column with imputation credits (i think i would do this) or does that go into the business income section and what to do with the imputaition credits then? 
Or i might even ring the ATO about this too. They are quite helpful i found from my first call to them

Disclaimer: This is not advice in any way just my thought process at the moment


----------



## benn (11 July 2008)

korrupt_1 said:


> So have I've understood this correctly?
> 
> Traded atleast once a day for the entire financial year.
> Nett loss for FY: $100K (with $20K gains and $120K loss)
> ...






Hey Korrupt, i come to the same conclusions as you have in your post. However, that is just my opinion and havnt done this before so not sure how it will pan out. You could give the ATO a call, they are quite helpful i believe. I believe it really all hinges on you being classified as a trader. A private ruling may be the shot for peace of mind and is binding on the tax office in an event of an audit. It also shows you have taken care in your tax affairs by applying for a ruling rather than willy nilly calling yourself a trader and you remove the ambiguity


----------



## korrupt_1 (28 July 2008)

Well for this FY,.. I've decided to classify myself as a Trader and carrying out it like a business would.

This here helped me to decide that my actitivies were considered to be business like. The examples really helped.

http://www.ato.gov.au/businesses/content.asp?doc=/Content/21749.htm&page=1&H1

The advantage of doing this is that I now can claim a ton of stuff since I use my Study Room for my activities and get to claim what other Home Businesses get to claim.


----------



## Doris (28 July 2008)

reece55 said:


> It makes a lot of difference.....
> 
> Primarily, as a trader you hold stocks on a revenue account and as an investor, you hold them on a capital account. Both have advantages and disadvantages. For example, a trader, provided he/she satisfies the non commercial loss provisions, can claim a deduction for a loss. Investors obviously have their losses retained to offset against future capital gains. Traders also can use their portfolio as trading stock.






benn said:


> i rang the ato on this last week. i want to defined as a trader so i can offset my heavy losses against my other normal employment income.
> 
> for the non commercial loss provisions to kick in i have to make an *income from my business of share trading of $20k*. So this is fairly easy to get even tho this $20k is offset by zillions of losses. Anyway this is the way i interpret it.




Summary:

You can be a _trader or an investor_ OR both a trader and an investor.

*Trading*: 

You must make an *INCOME (i.e. sales) of a minimum of $20k* to claim your trading loss (at your marginal rate) against income tax paid from other income.

*Investing*: 

You must claim your loss against capital gains or else defer this (carry loss forward) until a tax-year when you do make a capital gain.


You CAN have a trading portfolio _and_ an investing portfolio at any one time.  

Define which stocks are in each as you go or have a headache sorting at tax time.

You do not have to be _one or the other_ in any one financial year.
.


----------



## Doris (29 July 2008)

Pommiegranite said:


> Hi all, I'd appreciate any input from someone who knows about my situation...thanks:
> 
> The last time I sold any stock was around December 2007. Prior to this I had been trading on almost a daily basis.
> 
> ...




As I explained in the previous post you can do your tax as an INVESTOR and as a TRADER.

The stocks you intend to hold for a few years as an investor will go into your _investment_ portfolio.  (Pay CGT on profits)

(Remember if you've held a stock for 12 months you pay CGT on 50% of your profit)
Losses are carried forward until you can offset a capital gain.


The stocks you decide were trades will go into your _trading_ portfolio.

You must have SALES of over $20k to be classified by the ATO as a trader.
(You can claim any losses off 'other income'.)


But...

As a *trader* you are running a business (you are trying to make money out of trading).
You can claim expenses for your computer and 'office' etc...

*To be a TRADER you MUST have an ABN.*

If you don't have an ABN you can get one from the Australian Business Register.  My accountant did this for me.

If you apply for one now this can be backdated to 1 July 2007.

You MUST quote your ABN in your tax return! (the TRADER section)


*If *your *sales* are over $75k then you must also register for *GST*.

If your sales are under $75k you don't have to register for or pay *GST*.

*As an INVESTOR you do not need an ABN... no matter how much your sales are.*

Cheers!


----------



## Trembling Hand (29 July 2008)

Doris said:


> *To be a TRADER you MUST have an ABN.*



Not true at all!!!!!



Doris said:


> You can claim expenses for your computer and 'office' etc...



Capital Equipment is not considered an expense. Be very careful with things like this. They most probably can be rapidly depreciated but most certainly purchased Equipment is not an Expense. 

As always DYOR.


----------



## korrupt_1 (29 July 2008)

I've heard that you can claim a % of your mortgage/rent, utilities, council rates, phone and insurance if you dedicate a room to do your trading. For example, my Study - where I trade from - is about 15% of my house, therefore I can claim 15% of the above as an expense? Is that true?


----------



## Trembling Hand (29 July 2008)

korrupt ATO.gov.au has guide lines on home biz.

It's a lot easier if you are renting. If you are paying a mortgage you may run into Capital gains tax problems on your principal residence.

But really this stuff is for a tax account. Have a look through the ATO website and make a list then trot off and ask them.

As the false points above show. As good as this forum is its not one that Tax advice should be sourced from.  :homer:


----------



## korrupt_1 (29 July 2008)

I hate navagating the ATO website - needs an overhaul... so hard to pin point exactly what you want. Anyway, I'll have a look.



Trembling Hand said:


> As the false points above show. As good as this forum is its not one that Tax advice should be sourced from.  :homer:




:iagree: true, true, true... but it is a good place to bounce ideas around and get general information before actually going to a specialist who may/may not charge you for the advice...

You TH.... are a wealth of information


----------



## Doris (29 July 2008)

Trembling Hand said:


> *To be a TRADER you MUST have an ABN.*
> 
> Not true at all!!!!!
> 
> ...






korrupt_1 said:


> true, true, true... but it is a good place to bounce ideas around and get general information before actually going to a specialist who may/may not charge you for the advice...
> 
> You TH.... are a wealth of information




Sorry TH...  You are wrong that I was wrong.

I put my tax into my 'business accountant' last week and the ATO has changed their rules.

I always use an accountant for my tax return as I also have an investment property.  And now that I'm trading again, after 15 years, I was very careful to find out the current rules before 30.06.08 and double checked on every item during the assessment appointment. 

*Yes, I totally agree that you should seek professional advice!*

If you were a trader you should submit your tax return through an accountant.
... and claim their fee in the next financial year. (I always mean to pre-pay this before June 30 but always forget!)

Mine always finds deductibles I hadn't thought of... and double checks whether items should be deductible or depreciated.

e.g. depreciation of my PC and printer over three years (less % for private use);
... depreciation of my desk and chair over 10 years;
... deduction of a finance seminar + registration fee + mileage to attend and car park and toll road fees;
... printer cartridges and paper;
... % of heating, power and lighting costs for the time spent on research/trading;
... graph paper, pens;
... internet and data charges (% of use for trading);
... newspapers e.g Fin Rev and related finance magazines 
(only a % of normal daily newspapers as it is not generic and you can read the _unrelated_ news!)

I certainly have learned when you save $1.00 you have $1.00.
... but when you spend it on a tax deductible you only get your marginal tax rate back. So the spend must matter!

Yes, if you rent you can claim a % of your 'office'.  I don't bother here as you are right *TH*, the hassle of losing the simplicity of no CGT when you sell a house is not worth paying the accountant to keep records.

I do not profess to be an expert on tax... but my accountant is!


----------



## Trembling Hand (29 July 2008)

Doris not sure where you are saying I'm wrong. 

Equipment purchases are not an Expense!! like you have stated two post ago. You cannot go and purchase a computer for trading then deduct that from income as an expense.

And you don't *Have* to have an ABN to be deemed to be carrying out a biz.


----------



## korrupt_1 (29 July 2008)

Trembling Hand said:


> And you don't *Have* to have an ABN to be deemed to be carrying out a biz.




geeze wiz... reading the ATO/ABR website is making my head spin...  

http://www.ato.gov.au/businesses/co...c=001/003/021/001/008&mnu=59&mfp=001&st=&cy=1

The gist i'm getting is that you don't have to have an ABN... but if you are making >$75,000 then you will need to be registered for GST which means you will need an ABN....

(????) 

this one is in the too-hard basket... must go get real professional advice...


----------



## Doris (30 July 2008)

Trembling Hand said:


> Doris not sure where you are saying I'm wrong.
> 
> Equipment purchases are not an Expense!! like you have stated two post ago. You cannot go and purchase a computer for trading then deduct that from income as an expense.
> 
> And you don't *Have* to have an ABN to be deemed to be carrying out a biz.




My accountant said that to classify myself as a trader for tax purposes, as this is deemed to be carrying on a business, as I am endeavouring to make money, I now *need an ABN*.

Income (sales of stock) must be more than $20K. (otherwise it is classed as investing and a loss will be carried forward to next financial year.) 

She has applied for it for me and it will be backdated to 1 July 2007.

I use my PC to access my trading account and information/data etc thus I can *claim depreciation of it over three years* (less the % for personal use.)

All the items I listed (and more) have been claimed... for deduction or for depreciation over time (as exemplified) as I use them in order to trade.


----------



## Trembling Hand (30 July 2008)

Doris I really don't want to get into some argument that is really for each person to get professional advice about.

But from your first post it has to be pointed out that an asset can only be depreciated once it is paid for. If it isn't a lease purchase and you buy it from within the biz that will first be deemed a capital purchase. Which is in effect a profit which you may have to pay tax on. Only then can you depreciate it. 

Your statement that you can buy equipment and then claim it as an expense is a common mistake that can lead to tax problems. Yes you will claim depreciation on it but its not as simple as an expense.

also from the ato,


----------



## Doris (31 July 2008)

Trembling Hand said:


> Doris I really don't want to get into some argument that is really for each person to get professional advice about.
> 
> But from your first post it has to be pointed out that an asset can only be depreciated once it is paid for. If it isn't a lease purchase and you buy it from within the biz that will first be deemed a capital purchase. Which is in effect a profit which you may have to pay tax on. Only then can you depreciate it.
> 
> Your statement that you can buy equipment and then claim it as an expense is a common mistake that can lead to tax problems. Yes you will claim depreciation on it but its not as simple as an expense.




I do not get involved in arguments.  It's a sport I choose to live without.

However, I do like to learn from others and discussion is healthy and edifying. 

I purchase my equipment from _other income_ - my principal occupation as a teacher, not from profits made from trading!  

I agree you could not claim for equipment you have not paid for!


I rang my accountant who rang the ATO who confirmed they like *traders* to have an ABN.  
A TFN is sufficient for my broker only.

The ATO told her to have me check their *ABN Entitlement Tool* on their website because:



> *Penalties for applying for an ABN if you are not entitled  	*
> 
> If you apply for an ABN and are not entitled to be registered you may be committing an offence under section 8K of the Taxation Administration Act 1953 by making a false or misleading statement regarding the operation of an enterprise.
> Persons found guilty of making misleading statements may be prosecuted.




They reiterated that if it is likely that my sales may exceed $75k then I need to register for GST well prior to reaching this level, quoting my ABN.

A TFN, only, is sufficient for investors.

To find this tool:

www.ato.gov.au

Put cursor on: _FOR BUSINESSES_ ... on the left menu. Click on 'business home page' from the drop down menu.

Click on _RATES, CALCULATORS & TOOLS_ in the 'What you Can do' menu section on the left.

Then... click on 'TOOLS' at the bottom.
then... click on *ABN Entitlement decision tool*

You can then complete the 'test' and it will tell you if you are entitled to have an ABN.  They also say to print out your 'test' as a record.


OR... *YOU CAN SIMPLY GO TO THIS PAGE TO FIND IT*:

http://calculators.ato.gov.au/scripts/axos/axos.asp?CONTEXT=&KBS=ABN_Entitlement.xr4&go=ok

You click on START and then click YES or NO to each question and a few minutes later you know.

Perhaps someone with experience can confirm that with >$75k of sales you can claim a rebate on the GST you pay with each brokerage fee? (provided you have an ABN and register for GST well before you near this level)

I very much doubt I'll get to that level this year!


----------



## blablabla (4 August 2008)

Doris said:


> To be a TRADER you MUST have an ABN.
> 
> If your sales are under $75k you don't have to register for or pay GST.





Hi Doris,

Later posters have already refuted your assertion that to be a trader you must have an ABN, but I'm not sure that this thread is very clear on the subject. I had a look in the ATO website and found ATO publication NAT 11306-06.2007 which is a brochure about ABNs.

On page 1 it states:- "If your business has a GST turnover of $75,000 or more (or $150,000 or more for not-for-profit entities) you must register for GST and you’ll need an ABN to do this. If your business has a lower GST turnover, it’s up to you whether you register."

You pay GST on brokerages, professional fees, etc but not on the cost of the shares themselves. So, to have a GST turnover of $75,000 your share trading turnover would have to be in the megamillions.

Note that if you are registered for GST your accountant will have more work to do and will therefore have to charge you higher fees. Oh dear. I will be happy to be proved wrong, but for most simple traders there appears to be no need to either register for GST or to apply for an ABN.

If you have a later ATO ruling that changes any of this then please post a link or the reference number of the publication.


----------



## Doris (4 August 2008)

blablabla said:


> Hi Doris,
> 
> On page 1 it states:- "If your business has a GST turnover of $75,000 or more (or $150,000 or more for not-for-profit entities) you must register for GST and you’ll need an ABN to do this. If your business has a lower GST turnover, it’s up to you whether you register."
> 
> You pay GST on brokerages, professional fees, etc but not on the cost of the shares themselves. So, *to have a GST turnover of $75,000 your share trading turnover would have to be in the megamillions*.




Hey BBB...

I had a look at your site and it does indeed say 'a GST turnover of $75,000 or more'!  
I thought you may have not recorded it correctly! 

You just can't rely on public servants sometimes!  (Blame their English teacher?)

What it should say is 'a turnover of $75,000'...
not inferring... *have paid* $75,000 of GST

i.e. If your *sales* are over $75,000 then you must register for GST. 
... and to do this you must already have an ABN.
... and register for GST well before you cross the $75,000 sales line.

You were quite astute picking up the anomaly!  

Will you notify the ATO they have published an error or shall I?


----------



## Doris (4 August 2008)

Doris said:


> Hey BBB...
> 
> I had a look at your site and it does indeed say 'a GST turnover of $75,000 or more'!
> 
> ...




BBB... I phoned the ATO. I'm glad my attitude was tentative! 

The wording is from the tax laws and is *an accounting definition*. 

"Accountants know (but not the general public?) *GST turnover* means *GST applicable income* not *GST exempt income*.

- exactly what my accountant explained... as I reiterated above.  Obviously she knows this _definition_ 

I was also told the ABN, whilst not compulsory for share traders, is advisable as it makes it easier to deal with them, government departments and financial institutions etc.  

I can't see myself using it but who knows.  Maybe it's for a check-up they have in their 'big brother system'?

My accountant did say I would not have to do business statements...  Phew!


----------



## white_goodman (4 August 2008)

im doing property taxation at uni this semester, lets just say put some time aside for reading cos its a mother... theres so many different rules and guidelines that its ridiculous


----------



## benn (4 August 2008)

ill jump in on this too. When i was working in business services, we went to regular training sessions. This guy was unreal how much he knew www.justtax.com.au. 
Anyway i recently dug up one lot of training material on the non commercial loss provisions and it had in there that for the $20k income rule, for share traders this does not work in the 'usual' way and you have to make $20k profit on your trades not just sell $20k worth of stock. To sell $20k worth of stock would be too easy and ato will disallow. 
I guess im lucky this year that i made $20k over a number of trades but also lost much much more, BUT still that $20k rule will kick in for me.
I will struggle to make $20k this year the way it is panning out also. 

Also on another note, i put in my private ruling a couple of weeks ago and tonight got home to a letter from the ato. Alas, it didnt have my verdict in it, it just said they received my forms and would get back to me in 28 days. Pff, it has been about that since i sent it in the first place. 

Ill write when i get a response from them and then post some of what i had in my ruling as might help others 

i also dont have an ABN as i didnt think it was necessary.


----------

