Sep 06, 2023 / News

Healthcare / Taxation

South Australia’s Payroll Tax Amnesty for Medical Practices – time is almost up!

South Australia’s Payroll Tax Amnesty for Medical Practices – time is almost up!

In recent years two key cases (Commissioner of State Revenue (Vic) v The Optical Superstore Pty Ltd; and Thomas and Naaz Pty Ltd v Chief Commissioner of State Revenue) have garnered significant attention in the health and medical field.

As a result of the rulings in these cases, health and medical practices nationwide are at risk of incurring significant payroll tax liabilities on certain contractor arrangements (relevant contracts) if deemed to be employees under each state’s relevant Payroll Tax Act. Accordingly, medical practices can be liable for payroll tax on contractual payments to health professionals who are operating as independent contractors.

New South Wales, Queensland, Victoria, and South Australia state revenue offices have now released their harmonised position and detail how contractor provisions will apply to health and medical business contractor arrangements. There has never been a more important time to review your contractor arrangements to determine your exposure to these rules.

Revenue SA and the Queensland Revenue Office have offered an amnesty period for General Practitioners only, covering the financial years 2018/19 – 2023/24, noting registration must be made to Revenue SA by no later than 30 September 2023. The rules and eligibility criteria around this amnesty are not straight forward and we recommend engaging your legal and accounting team to consider your circumstances, the rules and assist with your application, if required.

No such amnesty has been declared for NSW or Victorian medical centres.


Item Date Deadlines State

Amnesty registration

30 September 2023

29 September 2023



Amnesty coverage

1 July 2018 – 30 June 2024

1 July 2018 – 30 June 2025








Nexia Edwards Marshall has extensive experience dealing with state taxes and specifically health and medical practices. Our firm works closely with trusted legal professionals to offer a robust service to suit your needs. Contact one of our great people today to understand how we and our network can assist you.

The material contained in this publication is for general information purposes only and does not constitute professional advice or recommendation from Nexia Edwards Marshall. Regarding any situation or circumstance, specific professional advice should be sought on any particular matter by contacting your Nexia Edwards Marshall Adviser.