Chartered Accountants Australia and New Zealand (CA ANZ) has lodged a submission to the ATO on Draft Recipient Created Tax Invoice (RCTI) legislative instrument and explanatory statement (Draft LI and ES) issued on 17 November 2022 for public consultation. 

The ATO is proposing to streamline the current 51 Recipient Created Tax Invoice (RCTI) legislative instruments by replacing them with a single legislative instrument, the Draft LI, that covers all existing classes. Overall, CA ANZ considers it to be a positive measure. 

We are supportive of the decision to streamline, improve consistency and broaden the scope of the measure by extending it to three broad classes of tax invoices that may be issued by a recipient. 

We recommend that the Commissioner clarify in the Draft LI, whether the embedded RCTI agreement clause must use the exact prescribed wording or whether substantially similar wording already embedded in business systems since implementation in 2000 would suffice.