Chartered Accountants Australia and New Zealand has lodged a submission on the cross-border GST rulings GSTR 2005/6DC and GSTR 2007/2DC (the updated draft rulings).  Our submission was broadly in support of the updated draft rulings, subject to a number of queries and comments highlighting areas in which we believe the drafts could be improved.

Our general comments on both updated draft rulings are that:

1. Overall, we believe that the draft rulings achieve the objective of effectively streamlining and simplifying the rulings which improves their clarity as guidance documents.
2. We support the clearer, abbreviated, plain English titles to the draft rulings.
3. Placing the Table of contents upfront improves the structure and navigability of the draft rulings.
4. Whilst a lot of content and various examples have been removed, it appears to have been primarily necessary to reflect the law changes concerning the business to consumer (B2C) and business to business (B2B) amendments. 
5.  A sufficient range of examples appear to have otherwise been retained or incorporated into the updated draft rulings to illustrate how the amended law works, including by adding new guidance content and inserting alternate / modified examples.
6. The updated draft rulings are also more user-friendly as we believe they cover the key elements of the relevant provisions, yet remove a lot of unnecessary detail and weighty discussion present in the previous ruling, namely:
   a. Previous draft ruling
   b. How to read the ruling
   c. Explanation section.

We noted however that the non-consecutive numbering of Examples is confusing, and the numbering of paragraphs using capital letters after the paragraph numbers when new paragraphs have been inserted should also be considered and addressed.