Payroll Tax Amnesty for Medical Practices in South Australia

Payroll Tax Amnesty for Medical Practices in South Australia

Payroll tax applies when the total wages expense for a business equals or exceeds $1.5 million in a financial year. Medical clinics in South Australia have not previously been paying payroll tax for payments made to General Practitioners (GPs) who provide services to those clinics. However, recent case law and rulings have changed that.

However, following the recent case of Thomas and Naaz v Chief Commissioner of State Revenue [2021] NSWCATAD 2591 and Commissioner of State Revenue v The Optical Superstore Pty Ltd [2019] VSCA 197, RevenueSA released a Ruling changing how payroll tax will be applied to payments made to contractors engaged by medical clinics in South Australia.  For example, medical clinics who engage GPs as contractors will be likely liable for unpaid payroll tax unless an exemption applies.

In light of this, RevenueSA announced that medical clinics that successfully apply for the amnesty will not be required to pay payroll tax on payments made to contracted general practitioners between 1 July 2018 and 30 June 2024. However, this registration had to be made with RevenueSA by 30 November 2023, meaning it is now closed.

Thus, for clinic operators, from 1 July 2024 onward, GP wages tied to Medicare bulk-billed services may be exempt from payroll tax under the new regulation, provided specific conditions are met as outlined in Revenue Ruling PTA004 (v2).

How we can help

If you run a clinic which contracts GP doctors to provide medical services to the public (otherwise known as the Associate Model), we strongly recommend you review your business model and associated agreements, as you may still face historical assessments unless you obtained relief under statute or ruling.

We can help by providing you with advice about the current status of payroll tax administration as it relates to the Associate Model and review your current agreements in light of the new payroll tax policies. Contact us on 1300 654 590 or send us an email at wehelp@adlvlaw.com.au

 

The information contained in this post is current at the date of editing – 10 October 2025.

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