States

Payroll tax and medical centres

State rules differ and have changed; check your state. This page does not calculate payroll tax.

Thomas and Naaz

Thomas and Naaz Pty Ltd v Chief Commissioner of State Revenue [2023] NSWCA 40. Decided 14 March 2023. New South Wales Court of Appeal. The summons for leave to appeal was dismissed. Revenue NSW records the proceeding as 2022/00228050. The judgment date is 14 March 2023. The 2022 decision is the tribunal appeal, not the Court of Appeal.

Court of Appeal judgment ↗

Revenue NSW case summary ↗

The 2022 tribunal appeal, which is not the Court of Appeal ↗

StateOfficial pageGP amnesty or exemption
New South WalesRevenue NSW — payroll tax and medical services ↗Bulk Billing Support Initiative page last updated 17 March 2026. CPN 036v2 issued 2 December 2024CPN 036v2 — Relief to medical centres, issued 2 December 2024 ↗A rebate, not a blanket exemption, for payments to contractor GPs from 4 September 2024, if the medical centre meets the bulk-billing proportion in Commissioner’s Practice Note CPN 036v2: at least 80% in Metropolitan Sydney, otherwise at least 70%. Audits of GP practices paused from 4 September 2023 and restarted on 4 September 2024.
VictoriaState Revenue Office Victoria — medical industry ↗Medical industry page. The exemption is also stated in Changes taking effect on 1 July 2025, published 1 July 2025SRO Victoria — changes from 1 July 2025, published 1 July 2025 ↗From 1 July 2025, wages a GP medical business pays to employee and contractor GPs are exempt for the proportion of GP work that is fully funded. The page says this does not apply to allied health or dentists. Revenue Ruling PTA-041 is linked from that page for relevant contracts.
QueenslandQueensland Revenue Office — GP amnesty ↗GP amnesty page. Exempt-wages page published 15 September 2026Queensland Revenue Office — exempt wages, published 15 September 2026 ↗The amnesty page says payments to contracted GPs were covered up to 30 November 2024 where an expression of interest was lodged. From 1 December 2024, that page says wages a medical practice pays a GP, contractor or employee, are exempt under an administrative arrangement, and that the Revenue Legislation Amendment Bill 2024 made that change permanent. The exempt-wages page, published 15 September 2026, states the exemption as wages paid by a medical practice (other than a hospital) to a contracted or employee general practitioner.
South AustraliaRevenueSA — Revenue Ruling PTASA004 ↗Issued 12 September 2025, version 3, status currentPTASA004 describes an amnesty on contractor wages of certain medical practitioners up to 30 June 2024, and a bulk-billing exemption on wages paid to GPs from 1 July 2024 where the conditions in the ruling are met. The amnesty text says it does not extend to GPs engaged as employees, or to nurses, reception, admin, pathology and allied health.
Western AustraliaRevenueWA — contractor payments ↗Contractor payments guideThis guide does not state a GP amnesty or a GP exemption. It says contractor payments can be taxable when the whole relationship is like employment, and it points to Revenue Ruling PT 6.
TasmaniaState Revenue Office Tasmania — contractors ↗Contractors pageThis contractors page does not state a GP amnesty or a GP exemption. It explains relevant contracts and the exclusions in the Payroll Tax Act 2008.
Australian Capital TerritoryACT Revenue — designated medical practices with GPs ↗Designated medical practices page. The same exemption is on Changes for 2025-26, 24 June 2025ACT Revenue — changes for 2025-26, 24 June 2025 ↗Circular PTA041 — relevant contracts, medical centres (PDF) ↗From 1 July 2025 a designated medical practice is exempt on wages paid to a GP, employee or contractor, for bulk-billed services and some veteran and workers-compensation services. That exemption replaced a temporary amnesty which applied up to 30 June 2025. Liabilities up to 30 June 2023 on contracted GP payments were waived without an application. Circular PTA041 explains relevant contracts. It is not the exemption notice.
Northern TerritoryTerritory Revenue Office — payroll tax ↗Payroll tax pageThis payroll tax page does not state a GP amnesty or a GP exemption.

Read 14 October 2026. A later notice on the revenue office page wins.

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State rules differ and have changed; check your state. Thomas and Naaz is a New South Wales Court of Appeal judgment dated 14 March 2023. It is not a national rule.

Thomas and Naaz [2023] NSWCA 40 ↗

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  • A wage threshold or a rate
  • Insurance and accounting fees

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