Facilitator: Okay, good morning everybody, thank you for joining us for the webinar this morning on GST on low value transactions and some other interesting trade issues that we’ll get updates from from our speaker, Andrew Hudson. So Andrew’s a partner at Rigby Cook, and last year in about August we asked Andrew to introduce our customers to the new legislation and what was coming out around GST on low value transactions, particularly those made online, because we knew a lot of our customers were engaging in that way. So I’ll hand over to Andrew to get started.
Andrew Hudson: Thank you Jos. Good morning everybody. Good morning from Melbourne, which sadly isn’t nelson in New Zealand where I was three weeks ago. I keep asking we do the webinars from there, but we still haven’t been successful in that. However, we’ll deal with Melbourne.
Thank you for joining this morning. We did do a session last year on the principles behind the idea that Australia would be introducing GST on low value transactions and the potential impact on New Zealand and small business selling into Australia, [00:01:13] or indeed big business as the case may be. Since that date it’s now been clarified, the basis upon which it’s going to be assessed, and some of the procedural materials are now available. It will be starting on 1 July, so there’s really nowhere to hide from this I’m afraid at the moment. So I’m not saying you should all go out and panic about this just yet, but by the same token we need to be aware of the fact that it is coming into effect, it will be an expectation, even using low value transactions, you’ll need to do an account, you may need to register for GST, And you may need to do an accounting into the Australian system.
And I can say that I’ve recently been co-presenting on this topic with the Australian Taxation Office. Oddly, they’re very excited about the concept, because we’re the first country in the world to do something like this. It’s not always probably the best way to be first, but we are, and the rest of the world is watching quite carefully, and they are being very aggressive about their enforcement strategies. So even to the extent you think “Oh, I’m not going to register and they won’t know”, the ATO has said it has the capacity to register you anyway, and to issue an assessment anyway and to have access to your bank accounts, and they are working with overseas tax authorities as well. So I guess my aim has always been to get it right in the first place.
But before we start today just a couple of other things. We will be talking beyond GST on low value transactions and other trade related issues, one of which you should be aware, hopefully you’re aware by now that there’s a proposal floating around in New Zealand that it too will be going to apply GST on low value imports. [00:02:45] It’s only a proposal at this point, there’s a discussion paper that’s been issued for comment by the affected parties. Can I encourage you to do so? I was presenting in Nelson with New Zealand customers on these topics last week, and there’s a lot of interest about it, so you should be mindful of that.
There will also be a new New Zealand Customs Act, which comes into effect on the 1st of October this year. The Act is in place, it’s received Royal assent, so it’s going forward. [00:03:12] We also are working now on part of a stakeholder advisory group, a reference group that’s working on the development of various regulations associated with it, so we’re looking forward to finishing off those regulations. But please be aware that as of 1 October things will change, and there will be a new legislation. And on that topic as of 1 July this year New Zealand will be implementing its single window for reporting. Now that won’t probably affect a lot of you directly, but your service provider may well come back to you and say “We need to register separately, we need to transact differently”, [00:03:45] there might be a different form of report it needs to complete. So I’d be asking them are there any changes they will need to do that will apply to import and export as well.
A couple of other things that have cropped literally over the last 24 hours, well, over the last couple of weeks and in particular with the EU. And over the last 24 hours the European Council has approved the EU to enter free trade negotiations with Australia and with New Zealand, and they’ll be coming out to start negotiations next month. So again, can I suggest you engage with NZTE and with your Ministry of Foreign Affairs and Trade. They’ll be very keen to hear from industry to see what they want and what sort of advantages they want, what sort of issues they want resolved, and how we go about doing it. It’s really hard to change a free trade agreement once it’s been negotiated and it’s in place. I’ve managed to do that occasionally but we’d much rather people had their say now. I know that Foreign Affairs and Trade is out talking about TPP11, and I’ll come back to that later. [00:04:45] But I think now’s the time to be making your interest known, and making your shopping list if nothing else to be available so you can handle it from there.
And one other major change which came out of our Australian Federal Budget a week or so ago, we’ll be implementing some new levies, biosecurity levies on containers being imported into Australia. There’ll be significant changes both on containers and on break bulk, [00:05:12] so there will be a significant additional levy on top of which all of our stevedores are adding in infrastructure charges. So the cost of getting goods here, going across the border it’s not purely GST on low value transactions, that will be the issue, which is mainly an air cargo issue, it will also be movement of goods by sea. As of now there are some new charges being paid to stevedores for infrastructure charges, and as of 1 July there’ll be a significant additional levy. [00:05:42] It’s got nothing to do with costs recovery for existing biosecurity testing, that’s already covered. It will be effectively a sinking fund or a contingency against something awful happening, such as our recent experience with the prawn imports into Australia. So be mindful of those things.
So I will now start what is in the great legal tradition hopefully not death by PowerPoint, but certainly a PowerPoint. As Jos said - [00:06:17] there we are, that’s a little bit about the firm. We work closely with New Zealand Trade and Enterprise, and we’ve been very lucky in doing so, so we call ourselves a full service firm, which means we cover most things that you might have a need for. That’s me, I’m sorry about that photo, that was my previous version of the sideburns. I’ve got a revised version at the moment. Anyway, what I’ve put in there are some of the details about some of the work I do. I’m on the Board of the Export Council of Australia and the food and beverage importers. [00:06:46] They also work closely with the freight forwarding and customs broking industry, and I sit on a number of the government advisory committees regarding trade and customs and dumping and the like. So all that means is I spend a lot of time being a trade all nerd, which I guess is good on occasion, but not always. And I have included as part of that, I’ve been working with CBAFF, which is the New Zealand Customs Brokers and Freight Forwarders Association, working with them on the new customs legislation into New Zealand, and attended the recent CBAFF conference on international trade and related issues that took place in Nelson quite recently.
So topics for today, the proposed new regime for collection of goods and services tax on low value transactions. Implementation of the provisions. Other Australian trade law issues, and developments in the New Zealand trade agenda, which you might not be aware of, but it’s as well to know about things coming down the pipeline so you’re prepared for it, but importantly engage with your government contacts, so New Zealand Trade and Enterprise, the Ministry of Foreign Affairs and Trade and similar bodies, because they really do need to hear from you about issues that are cropping up. For example in Australia a lot of our wine going into China has been stopped at the border for additional border testing for Chinese buyers’ security requirements, it’s creating some ruction. So if something else like that crops up, what we call a non-tariff barrier, certainly report back on those issues, because it’s only if government knows about the issues that it can actually deal with them.
Okay, the proposed new regime for collection of GST on low value transactions. Now, to start with, our friends at the tax office have been at pains to say this is not a tax on the goods, as customs duty is a tax applied to the goods. But it’s a tax on the supply, or the consumption of low value goods by import. [00:08:45] Now, it’s not going to apply in all circumstances, and I’ll hopefully give you some examples. But where it’s going to basically affect New Zealand importers coming into Australia, it will be as a supplier, or if you’re running a distribution platform like some of the online selling platforms, or you’re a re-deliverer of goods into Australia, which doesn’t happen a massive lot from New Zealand. The bottom line is if you believe you sell over in A dollars more than $75,000 to consumers online in Australia, and if you then – and that is to consumers, then you’re probably going to have to register and account for the GST, you’re going to have to charge it, you’re going to have to change your websites and add on a GST component, then you’re going to have to charge it and then account for it back to the tax office here. It won’t apply at the point of importation, but there will be a reporting requirement as part of your registration requirements. So be mindful of those tests, and if you think you’re close to $75,000 which is our threshold for registration, [00:09:45] you should really be thinking about registering and getting yourselves sorted out in the system here.
So ultimately it’s a consumption tax, goods and services tax. We’ve had it for nearly the last 12 months as far as it applies to electronic services, so what is known as the Netflix tax for example. So my Netflix subscription went up by 10% because I’m suddenly paying GST on what’s being provided from outside our borders. So it applies to goods and services which are connected to Australia, the rate is 10%. [00:10:13] There are exceptions, GST free supplies, so some goods are naturally free of GST, some basic foodstuffs, medicines are exempt from GST in the first place. And some input tax supplies, such as financial services. Keep in mind too, this is intended to only operate on a business to consumer sale level. So if you’re selling to an Australian business, and it gives you GST details, and an Australian Business Number, [00:10:43] then you won’t have to account for it because it will be accounted for in the Australian system later on. And keep in mind too that some goods, even at low value, are already subject to GST, for example alcohol and tobacco.
The GST registration turnover threshold as I mentioned is $75,000, so that’s actually not a terribly high threshold. It’s the same threshold as here, the idea is to equalise the regime between Australia and New Zealand. [00:11:16] Sorry, between imports to domestic. Obviously it was driven by the Australian retail industry which said it needed to be on a level playing field together with imported goods. So it’s currently the same threshold.
So it operates from the 1st of July, so that’s pretty soon, to be honest. As I said, we’ve been talking about it for a number of years, and we’re really getting very close to it. And based on what’s been said by the Australian Taxation Office lately, I think we’ll find that they’ll be fairly aggressive in their enforcement and compliance provisions. So it applies to low value imported goods or low value transactions. It’s B-to-C, so sales to consumers. If it’s a B-to-B business, if you’re selling it to a business, it won’t attract GST, because the business will quote its Australian Business Number. However, if that business is buying goods that aren’t necessarily connected to its business, so the example might be that if you are selling to an Australian concreter company, but it’s buying golf clubs, they may not be connected with the concrete business, or not normally anyway. So that might be a situation in which you’d have to make further inquiries. It all comes back to your reasonable belief in the transaction. If you have a reasonable belief that the transaction is to a business, then you’ll probably be okay. But we need to keep good records of this.
The supply must be connected to Australia in some fashion. Coming into Australia, it makes it fairly connected to an Australian consumer. Businesses that might supply or assist the goods, the consumers are affected. It’s the merchants or the suppliers who sell the goods directly. EDP is electronic distribution platforms, and we’ll come back to what they are and what they aren’t later on. But it’s a lot of the larger, so your Ebays and your Amazons and the like who they’ll be the ones accounting for it. So if you sell for example through an EBay or an Amazon, it will be the one doing it. Your sale through that process won’t be caught. So it’s what we call here – and it also applies to re-deliverers, so for example with America, American companies sometimes don’t sell online if you’ve got an address in New Zealand or Australia. So what we call re-deliverers set up a post office box, basically in the US, it gets delivered to that address, and then it gets re-delivered from there to Australia or New Zealand as is appropriate. And Australia Post for example has a fairly significant business around this.
But the term you’re going to hear, it’s a vendor registration model. There were other models that were looked at closely about putting the obligation on the freight forwarder or the customs broker, or even putting it on the person doing the delivery at the end, being Australia Post, or the delivering person at the end. Ultimately though the decision that was made in Australia was to adopt a vendor registration model. Now, that’s being watched as I said closely around the world, and in particular it will be looked at very closely in terms of what the model will be in New Zealand [00:14:15] when New Zealand starts, if New Zealand gets to impose this sort of responsibility. However given that Australia is setting it up and Australia is going to be running with it, and people will be able to learn from those experiences, you probably think that when New Zealand implements it it will do so in a similar fashion to be consistent. But people are watching to see how it goes, indeed whether it crashes or not.
So it’s a two-tiered system. If the goods are under $1,000 or less or the transaction’s $1,000 or less, [00:14:44] it’s potentially a liability to remit GST. It will depend upon which is to charge it, add it, gross up the price to add the GST, and remit it probably in a monthly report. It will depend upon the goods, it will depend upon how it’s transacted and the consumer is, but you suddenly have a liability where there wasn’t one previously. If the customs value is more than $1,000 GST is still payable by the importer. So you’ve got a two-tiered or two-regime system. Under $1,000 if the GST applies, [00:15:15] it’s imposed on the overseas supplier or the distribution platform or whatever the case may be. Over $1,000 on the transaction it will be imposed on the Australian importer. So there’s a tension between those two things. I could spend a long time talking about the history and philosophy of online taxation, but I’m not going to do that for you.
But anyway, sales to Australia, so it doesn’t affect related issues. Sales to Australia and GST registered entities will in the large part be GST free. Still free of customs duty, we’re not dealing with the customs duty issue, [00:15:47] exemptions are still in place for certain goods, so if you’ve been selling goods which would be exempt, foodstuffs, medicines and the like, pharmaceuticals in some cases won’t apply, and tobacco and tobacco products and alcohol are still subject to GST, they always have been regardless of value.
Over the low value threshold, we still continue to collect GST and customs duty under a full import declaration. Under the threshold previously it’s been reported by what’s called a self-assess clearance declaration. [00:16:16] that form of document will still be used, but it will be altered a bit, it will have the name of the, if you like the vendor who’s registered, and details of the transaction including its dollar value and so forth. And that’s already available on the system, so hopefully your service providers, be they freight forwarders or customs brokers into Australia or whatever through the distribution platforms, hopefully they're already going into the Australian system and checking how it may interact and how it operates. [00:16:46] And there’s no double taxation. If the importer pays it on the sale, then you won’t be paying it at the point of import.
So again, sales to consumer, not registered for GST, it’s on the supplier, the supplier distribution platform re-deliverer. And there are a few examples, and I won’t go through them here with you now, because we’ve got a bunch of stuff to go through. But I have at the end given you some links to some example material from the ATO and from the [00:17:15] Border Force here that we’ll go through. In particular the ATO has got some guidance and some rulings which are very helpful in terms of transactions for different people in the supply chain.
So what’s a distribution platform? Basically you as a merchant or a supplier won’t be responsible where you go through an electronic distribution platform, or through a re-deliverer. So a distribution platform is if you go through a website of someone else, internet, portal, gateway or store. [00:17:44] So if it allows, if you use a facility that allows you to make sales to end users, and you go through that facility, the person operating the distribution platform will be the one responsible. So you won’t be responsible for worrying about GST on that transaction. And if you do both, if you sell direct or you go through ad distribution platform, sales you do through a distribution platform won’t actually be included in your threshold to see whether you get up to $75,000. [00:18:15] It won’t be a distribution platform if it’s only things like a payment system. So if it’s only a way of – Paypal for example. In those cases that won’t be a distribution platform, all it is is facilitating the transaction of money.
A re-deliverer, we’ve talked about this. It probably doesn’t happen a lot, there’s not a lot of internet geo-blocking between Australia and New Zealand, so I best not worry and confuse the issue about that. Now, at this point we thought we’d break up this at different stages and see whether there were any questions yet. I mean, by all means ask questions at any stage, I’m a lawyer and I’ll talk endlessly if given the opportunity. But if you have any questions here? Is there any questions at this point on the system?
Facilitator: No, we haven’t received any through the system.
Andrew Hudson: Okay. Well then we will charge on through the rest of it. So there we are, in summary, GST on low value transactions, you might have an exposure as of 1 July. This is the time, if you haven’t done so already, get some advice, work out whether you need to register and work out how the transactions will work. Because if it’s not done properly, it’s not just a compliance issue with the ATO. If a self-assessed clearance declaration is used and it’s incorrect, you’ve also got an exposure to the Australian Border Force in terms of an incorrect statement. And even if there’s no customs duty at stake, and even if there proves to be no GST payable, you can still be penalised for an error in a statement to customs, to the Border Force here, so just be aware of those potential liabilities.
Okay, implementation of the provisions. So we’re getting into after 1 July, it will go through a [00:20:01] cargo report or a self-assessed clearance declaration. So keep in mind that there’s a hierarchy. As I said before, if the operator of the distribution platform is liable for the GST, you won’t be responsible for it. So you need to have a really close look at the relationship you have with the parties through whom you sell the goods, and work out as between the two of you who’s going to be liable for the GST. On most occasions your distribution platform isn’t just about payment, it’s about transacting the sale, where they basically we’ll do it all and we’ll give you some money back later. In those cases it will mainly be a distribution platform, and therefore will have the primary obligation. But by the same token, if you’re dealing with a re-deliverer, if it’s a re-deliverer through a distribution platform, the distribution platform will be responsible, not the re-deliverer. But I do know that a lot of New Zealand SMEs do sell direct through their own websites and their own portals, so there you’ve got a direct responsibility as opposed to going through a third party. It might be some people are terrified by this whole idea and might actually revert to a distribution platform. That’s a fairly significant change to business practices, but you’ve just got to turn your mind to it. Keeping in mind the threshold, $75,000 in A dollar terms, so it’s not a particularly high threshold, especially with some of the high value goods which are being sold by SMEs out of New Zealand.
Okay, so you need to account for GST if you’re registered or required to be registered. You might already be registered, you might already be selling into Australia and be registered for GST, in which case no real drama. $75,000 as I said before is the threshold. $150,000 for non-profit bodies. So if you’re an incorporated association, a not for profit body selling into Australia, your threshold will be double that. I’m not quite sure how many of them there are within the SME world, but certainly be aware of it. Now, we’re talking $75,000, so we just keep in mind that if you’re selling it through a distribution platform, you won’t be responsible, the distribution platform will.
So are you affected? Are you a supplier? If you’re doing direct sales of $75,000 a year, well then you’re going to be caught by the process. If you are an electronic distribution platform, will this suddenly mean that you continue to provide services? You might get a distribution platform that says “Actually, we’re not interested in being a distribution platform and responsible for payment of the GST. [00:22:32] We’re going to actually make you do it directly. We’re going to be merely here to facilitate the payment of money, rather than the sale itself”.
There are two types of registration for GST. There’s a, if you like a ‘lite’, L I T E form, which I hate, but it’s a light form that you won’t get input credits or an ABN. There’s a more formal full arrangement, but it brings you on shore effectively. Will you be changing your prices to include GST? [00:23:00] So if you’re running your own website, your own sales portal, you’re suddenly going to have to include a liability for GST. And you’ve got to be careful about that, because when you’re selling into Australia, if you incorrectly describe the amount payable, or you don’t include the GST amount, it could be misleading and deceptive type issues. So we want to make sure we’re properly declaring the potential price. Make sure whoever’s doing the reporting of your cargo that they’re aware of the self-assessed clearance declaration and the new form that’s going to be used.
So I’d be having a chat to your freight forwarders and your customs brokers who facilitate all this trade for you to make sure that they’re saying the same thing that you’re saying. So make sure that if they’re reporting that you’re liable for the GST, make sure that you’re in fact appropriately registered over that threshold. So again, I’d encourage you to have your discussion. As I said before, I do a lot of work with the customs brokers and freight forwarders out of New Zealand, [00:24:00] they’re a really expert group of people, have that discussion with them, and discuss how it’s going to be reported, which sort of forms they’re going to use, whether they believe you are in fact the supplier and liable for it, or whether in fact they believe the person you might help with your trade is in fact the person liable.
Two taxing regimes, as I said before. It does create issues for compliance, and there’s been a lot of, if you like, fairly jaundiced comments made about the process in saying “What about if there’s 14 entities and they’re all just under $75,000, or there’s entities that don’t register, what’s going to happen to them?”. Well, the tax office has been pretty clear about that. I was in a government meeting with them recently, in which they said that more people had registered than they had anticipated. They figure on recovering more money than they believed they’d be recovering out of this arrangement. They’ve been pleased, oddly enough, the whole idea that a taxation authority would be happy, but they were happy with the idea that [00:25:00] people are registering and taking this seriously.
And they have a lot of ways. People say “Well, are they going to go overseas, are they going to turn up in China and give a GST bill to a Chinese entity?”. Well, the bottom line is they will be. And they won’t have to do that directly. They can do it here. They can force compliance here. They can register an entity for GST here. Even if they don’t register themselves, they can do it unilaterally. They can actually then turn around, and if those companies have monies in Australian accounts they can take the money out by way of what they call a Garnishee Notice. [00:25:33] They can notify other agencies overseas, they work closely with other tax authorities in other countries. And if they believe there’s been non-compliance overseas, even though the ATO might not venture into another country, they’ll have a quiet word to Inland Revenue in New Zealand or the tax authorities in America or the like. Basically what they’re saying is that they will still issue demands, they will hold proceeds, they will behave in a way that they think is in their best interests. [00:26:00] So as much as people say “No one’s going to bother about this”, they will. They are going to be watched very closely on their reporting.
So in the Budget towards next May there will be a report about how much they’ve recovered, how compliance has gone, where the soft parts of compliance are or where the difficult parts of compliance are. And if they find that certain – they will know, the reality is they will know pretty early whether people have registered where they should, or haven’t registered where they should. They’ll have an idea about who is selling a lot of goods into Australia using the low value transaction scheme. So you’re not paying GST or duty. They’ll have a pretty good idea about it. They’ve got big computers with lots of different coloured lights on them. So my understanding is they’ve got a pretty good handle on who should be registering anyway. And just because you might register or you might establish a new entity to do the sales, or more than one entity, they’re going to find out one way or the other. So we’d rather you comply from the beginning, rather than have the nasty people from the tax authority who are only doing their job dealing with it.
There are some links there. We all like a good link. ATO pages there, there’s the ATO pages, and at that ATO page what you’ll find is there are three different rulings, or three different guides, one if you’re a supplier, one if you’re a distribution platform, one if you’re a re-deliverer. There’s also a page there for those of you who happen to be customs brokers or freight forwarders. And it’s worth having a look at that, because that’s what your service provider’s going to be looking at. [00:27:30] So worth looking at that.
ABF is our Australian Border Force, which is part of our Department of Home Affairs, they’re the ones in the uniforms carrying the guns. So there’s a Border Force, there’s a main Border Force page there. That includes a link to a release. That’s about people who are going to be reporting into the customs system directly now. There’s a specific release. We have some technical issues about how to report into the Australian customs system if you’re going to do it yourself. So again decisions need to be made, are we using service providers, are they registered, are they ready, are we going to do it ourselves, or we’ve done it ourselves but we need to do it differently.
DHA, Department of Home Affairs, there are some notices there, numbers 13, 14 and 15 of this year. Slightly tragically I look at the Department of Home Affairs website pretty much every day to see if there’s a new notice, and there’s three for you. So again, we’ve got some significant resources available to you to ensure compliance. So even if you’ve done nothing to this point, and I’m sure there are a lot of people who haven’t, we all resist change when it comes to our busy lives and how we operate and the like. I’d be setting aside some time to do some homework, work out is it going to affect my business, or am I selling through a distribution platform? Or if the distribution platform comes up and says “We’re doing it differently because we don’t want to pay the GST”, then you’ve got to work out how we’re going to deal with it in terms of the logistics of the thing.
Because we want you to keep trading. We want you to keep selling your wonderful goods to Australia, so we’re encouraging you to do it. The aim of this and everything else we talk about is front end. We’re not dealing with crisis management here, we’re not dealing with a case or a decision, we’re trying to get you ready for it at the beginning, which is almost the most cheerful way of doing it. And if I could just make the other point, the Border Force and the ATO have said that they won’t be stopping transactions for people, in other words they won’t be holding things at the border. [00:29:29] However if, and I won’t drag you through this, but the Border Force has what’s called a compliance continuum. If you engage, if you try and do the right thing, if you educate yourselves, you’re really not going to have many issues with the Border Force, they’re going to be disinclined to give you penalties, the ATO will be much the same. Keep in mind if you don’t pay the right amount of tax, the ATO here can charge interest and penalties automatically. However, if they believe you’re reckless or you’re turning a blind eye to it deliberately, or you’re deliberately being naughty, [00:30:02] they have a lot of options available. And I wouldn’t recommend going down that path at all. And none of you would, and of course because you’re dealing with government you’d be wanting to operate in a happy state going forward. It’s the last thing you need to deal with, with your business. Now, have we got any questions on that one?
Facilitator: We do have a few questions now, which is great. So Colleen has asked if you have a New Zealand company with an ABN number already, does that mean that you are automatically registered?
Andrew Hudson:Well, I would check that. It won’t happen automatically, but if you’re already registered for GST in Australia, then you should be fine.
Facilitator: Basically you can look at it as a two stage process, so you get your ABN, and then you register for GST.
Andrew Hudson: Correct.
Facilitator: So you’d need to look at that.
Andrew Hudson: Yeah, and I’d say if you’ve got an ABN you’ve still got to register for GST, and get your paperwork up and running, speak to your friendly neighbourhood accounting type person.
Facilitator: Yes. Dan has asked “I sell directly to Australia through my own website, and will be below the annual threshold of A$75,000. Is Australian dollar GST still payable even if I’m not registered?
Andrew Hudson: No, because you’re below the threshold, you don’t need to register. However if you do enormously well and suddenly you’re likely to get over the $75,000 threshold, then I’d start getting yourself sorted. But if you reasonably believe you’re not coming over that threshold, then there won’t be an expectation for you to register, it will still need to be charged on it. So registration is dependent – so it’s again a two stage thing. The transactions will still attract GST, but you won’t need to register for it.
Facilitator: Great. Okay, Don has asked we have B-to-B and B-to-C sales in Australia. Does the threshold of $75,000 apply just to B-to-C sales?
Andrew Hudson: That’s my understanding, it does apply to B-to-C.
Facilitator: Solly – if you have agreed that your Australian-based distributor will honour the new GST but does not, who holds liability?
Andrew Hudson: You do still, because your primary responsibility is to government, because you are the supplier into Australia. So they might reimburse you for example for the GST, or they might say [lost audio]. However you tie it up, if it’s a B-to-B then you might not be liable for it all. But if it’s a B-to-C and you’ve got an exposure, then the exposure will be for you directly, [00:32:38] and the fact that you might have passed that on to your distributor is largely irrelevant to the ATO. So I’d be making sure you report that properly in the first place.
Facilitator: And we have a couple here from Kylie, we might go to the second part first which I think will be quite quick for you to answer. Is the threshold of $75,000 for the total exported to Australia, or just the annual sales altogether on a website?
Andrew Hudson: It goes to the annual sales by the vendor entity. So if you go back a bit in the slides, and we’ll circulate those slides, there’s actually a bit about how you work that out. But generally it’s to do with these B-to-C type sales across a year, basically, through the website.
Facilitator: Okay. And Kylie actually does have an e-commerce platform, so her clients are the merchants. Are they responsible or liable for the GST compliance?
Andrew Hudson:No, it will probably be you if you’re a distribution platform. So if I could encourage you to go back to the slides, and indeed all the links I’ve given you about what’s an electronic distribution platform. It depends upon whether you’re a distribution platform, but if you’re a distribution platform you’ll be the party responsible for GST compliance. Your suppliers are relieved from that, because you’ll be the vendor effectively through which the sales take place. So you need to look really carefully at what you do. Are you merely providing a payment option, or are you really facilitating the sale? [00:34:10] If you’re facilitating the sale, and you actually come under the heading of the electronic distribution platform, and it goes over the $75,000, which I’m anticipating it will, you’ll need to start charging the GST on the sales that happen through the portal.
Facilitator: Okay. So they’re all of our questions so far, so we can go onto the next one.
Andrew Hudson: Okay. So moving away from the overwhelming excitement of goods and services tax on low value transactions. Okay, we’re now going to talk about other Australian trade law issues. So I am in fact as you’d expect a lawyer, so there’s some other Australian trade law things that are happening as of 1 July. So we’re still having issues with asbestos imports. So there’s probably not a lot of that coming from our part, but if you are facilitating for example, bringing stuff in from China or the US, so if you might source product in China or the US and the EU, it has to be totally free of asbestos. There have been some issues recently with motor vehicles, classic motor vehicles being brought to Australia which have actually been stopped and taken apart, because the concern was that they might have a non-compliant asbestos element to it. It also applies to things like building products, electronic cabling of all things, switches. If there’s asbestos, or there’s a risk of asbestos, it can’t come in. So that’s an important thing.
And keep in mind the rest of the world, where it says ‘no asbestos’, that doesn’t mean there’s no asbestos, it means that they have a tolerance of 2 or 3% potentially in the US for example. We don’t have that. We have zero is zero. I think the only asbestos fibre we’re allowed to bring in is something that comes out of the Australian Antarctic Territory. Very little of that is coming in. [00:36:00] So we don’t want to worry about it. So basically speaking, and even if you come out of America and you’ve got an American certificate that says it’s free of asbestos, that won’t hold up, because it will have to be certified to Australian standard. And the Border Force has been enabled to stop everything, examine it, it focuses on different types of goods at different times. So if you are particularly concerned about that – it originally arose out of issues in building products, but it does apply to a much broader scheme of things, so be aware of that.
Compliance issues, I won’t bore you with a lot of that stuff. [00:36:30] The China free trade agreement for us is still creating some issues. Voluntary disclosure is an issue here. Now, keep in mind here, and this is one of the unhappy parts of the practice, sometimes things go wrong. And sometimes you discover things go wrong. And when it comes to the Border Force, my suggestion is that’s the point at which you consider how to disclose and do the disclosure, even if it means you’ve got to pay duty. Because if you disclose properly, you avoid the additional penalties. Keep in mind too that your customs broker in Australia, [00:37:01] your Australian customs broker, a licensed customs broker, because of their licence they are obliged to report to the Border Force a transaction where they believe there’s been an error or an underpayment of duty. And I had a case yesterday where the client is a freight forwarder and customs broker, they’ve got a new client who’s come from another customs broker, they’ve looked at the transactions and said “Hang on, you’ve underpaid customs duty”. The client has said “Well, it’s not our problem, it’s our previous broker’s problem”. Not the case at all. [00:37:30] Even if the broker hasn’t done the transaction, it’s still obliged to report or it loses its licence and it commits an offence. All the more reason for there to be voluntary disclosure. If you voluntarily disclose you can avoid most of the compliance or infringement issues, but there still may need to be duty payable, so we just need to be mindful of those things.
We have a fairly strict compliance regime, we get good compliance updates once a quarter that tells you how many [00:38:02] infringement notices and the like and what they’re focusing on, if people are interested let me know, but there’s certainly a very high level of infringement notices being issued every year. A lot of that going around the goods that might be brought in [unintelligible 00:38:14] here. So just be aware of those sort of issues.
Dumping and subsidies issues, again, even though there’s no dumping as it’s been Australia and New Zealand, there may be issues, you might be a New Zealand company that’s facilitating the import of goods from China into Australia for example, [00:38:31] you might be facilitating the import of steel and might be buying steel in Asia and importing it into Australia into the building industry. Steel and aluminium are big risk issues because the measures in Australia apply very extensively. There’s also concerns now that people are buying out of Malaysia or Thailand, and the government thinks it’s really Chinese product, and it’s been done to circumvent the issues, so there’s circumvention investigations going on, and there’s prosecutions taking place. Be mindful, if you’re buying out of – and this is what the Americans are worried about as well, where they’ve got massive additional duties being put on steel and aluminium. If you are trading in steel and aluminium into Australia be really mindful, but also into the rest of the world, of these sort of liabilities and needing to comply.
Facilitator: We might comment on cider?
Andrew Hudson: Oh, cider’s always fun, yes, yes. Cider. Delicious but deadly when it comes to customs duties. There’s basically, under our regime there’s two levels of liability. Cider, if cider is cider and it’s only just the cider, in other words there’s no additives or flavourings, then the wine equalisation tax applies at the border. Wine equalisation tax, by the way, the regime is changing coming into Australia, and New Zealand wine sellers who had the benefit of the regime to allow threshold, [00:39:55] that’s going to change as well. But in terms of cider, if it’s pure cider, it doesn’t have an additive or a flavouring, then you pay at a wine equalisation tax level. If however that cider is treated as non-traditional, in other words it’s got a flavouring or an additive in it, then it’s treated as still cider, but it attracts customs duty at a much higher level. And we’re acting for a lot of people who’ve imported what they believe [00:40:23] to be just cider, and what’s happened is Border Force have said “Actually, what you had as cider and paid wine equalisation tax is actually subject to customs duty because there’s an additive or a flavouring. So there are real issues around that, and I know that New Zealand exports a lot of cider into Australia. I’m sure they’ve got that bit sorted, but just be mindful of that going forward.
In terms of some other stuff, creation of our Department of Home Affairs late last year, [00:40:53] middle of December, 20 December my recollection is we established our new Department of Home Affairs which incorporates the Border Force, it incorporates ASIO, it incorporates a lot of our intelligence and cyber security type people. So the Border Force still exists, it’s effectively the customs service under the Department of Home Affairs. The Department of Home Affairs significantly more powerful, influential than they have been previously. So keeping in mind it also covers [00:41:23] skilled people and migration as well.
Our Singapore free trade agreement changed a bit late last year, so again if you’re using that to bring goods into Australia from Singapore, you need to be aware of that. We’ve had our biosecurity report on prawn imports, and they have been blaming infestation on prawn imports, so there’s a very tough regime on bringing prawn imports into Australia. China has banned a lot of our recycling products going into China. So previously we paid levies and people would take our recyclable products overseas. [00:41:54] The problem is now the Chinese aren’t taking it, so it’s having to be dealt with locally. There’s a significant additional impost being put on people. Keep in mind so that may also apply, so people who have been facilitating the export of recyclable material to China, it ain’t going to happen anymore.
Australia and New Zealand have also taken WTO, World Trade Organisation, action against Canada. So even though we’re all part of the Commonwealth and we all like one another, we’re still going to the WTO saying [00:42:24] there are some laws in place in Canada which favour domestic produce unfairly everyone says over imported products. So that’s happening at the WTO at the moment.
There is of course the excitement over the TPP11, or the CPTPP, the Comprehensive Progressive Trans-Pacific Partnership, or the TPP11. It’s the original deal with America taken out, and there’s 22 provisions out of the original deal that have been suspended. [00:42:52] They’re mainly around intellectual property or pharmaceutical type issues. It does include New Zealand as well, so we’re looking at implementation issues now, theory late this year, early this year. Mexico’s already approved it. The lower house of the Japanese parliament has approved it. It’s currently before parliament in Australia before our joint standing Committee on Treaties for approval or ratification processes. I know also the New Zealand Ministry of Foreign Affairs and Trade is out on the road talking to people [00:43:23] in different district centres, regional centres about the TPP and how it will work and how it benefits us, so if you’re not involved in those discussions, can I suggest you will. It is going to go ahead. We’re going to get the approvals one way or another, I certainly hope. I don’t think it’s as evil as some people would have you believe. In fact I know it’s not, because I’ve been through it, I’m one of the few people who read the whole thing, lucky. And I do know the negotiators both in New Zealand and Australia, and they’re entirely excellent people, so I don’t have an issue with the conspiracy theories.
So there was [unintelligible 00:43:58] the 8th of March, also International Women’s Day, also my birthday. Obviously a big day in the world, for the approval process that is. There’s a lot more details out there, we’re happy to work with anybody to talk about implementation. But do be aware of it, the countries it’s going to impose – even if there’s no duty already, some of these countries we already have deals with. But in terms of the process, there are actually some really interesting provisions in there about SME, supporting small and medium enterprise obligations, [00:44:27] there’s provisions on labour standards, there’s provisions on a whole range of things, so they’re all worth having a look at.
What’s standard on 1st of July, what’s already in place. Penalties for the illegal logging regime. Now we have, Australia was a world leader, again, very bravely, in terms of the illegal logging regime. Now, the Americans have a slightly different system, and actually it’s interesting with illegal logging, [00:44:56] the concern is are these goods the product of illegal logging? And the Americans have a slightly similar but not identical provision. And in fact a number of years ago they prosecuted Gibson guitars in the US for breaches of illegal logging. But in Australia we’ve had an illegal logging regime, but it’s been what they call a soft entry, so in other words no one’s been prosecuted unless they were behaving particularly badly.
Now as of 1 January we have the regimes up and running. So on an import declaration there will be what’s called a community protection question. Your customs broker will be asked “Are these goods the product of illegal logging or has your client undertaken due diligence to establish that these goods are not of illegal logging?”. So you might facilitate imports from Malaysia or Indonesia or China, or you might be bringing in products out of New Zealand directly. Your broker will want to know that you have a program into place, a due diligence program, [00:45:55] which complies with the requirements of the Australian legislation to verify that the goods are not the product of illegal logging. So if you’re not across all those things yet, can I suggest you do so fairly rapidly, because if your broker doesn’t believe you’ve got due diligence in place, then he has to tick the box to say that there’s no due diligence, and that will attract all the bells and whistles that go off, so be mindful of that. Of course there’s no illegal logging in New Zealand of course, we’re fully aware of that, so we should be right here. [00:46:25] But at least you show you’ve got a program in place, and there’s a lot of material available on this.
Australia’s established an MRA with Hong Kong on the 1st of March under our Trusted Trader program, we have a Trusted Trader program. New Zealand has Secure Exports, but that’s largely just to exports. I was at the CBAFF conference in Nelson, and people in the audience asked New Zealand government “Are you going to introduce a Trusted Trader regime in New Zealand beyond Secure Exports?”, and the response was [00:46:54] “We’ve done a lot of homework, no, we’re not likely to be doing a Trusted Trader program out in New Zealand”. There is a secure trade lane initiative between Australia and New Zealand they’re working on at the moment. But Australia’s got a broadly based Trusted Trader system. If you’re doing a lot of trade with Australia, it is worth having a look at. There’s 170 members now of it, but the government wants 1,000 by 2020. They’ve streamlined the application process, [00:47:22] forms don’t take three weeks to contribute, about three hours now. You’ll get an account manager, you’ll get deferred duty, not that there is from New Zealand, but you’ll get some advantages going forward. And if you’re in the Australian Trusted Trader program, you’ll get benefits with other countries, so with Hong Kong, they’ve got an Authorised Economic Operator program, you’ll be treated as if you’re a member of that. We’re doing a deal, almost done with New Zealand, we’re doing a scoping study with America as well. [00:47:53] It will put you in the same position as if you’re a Trusted Trader in another environment, and that might give you some benefits, and certainly some more help. Worth having a think about. I present with these people all the time, and they’re nice people. So if you’re interested we can certainly help with that.
There are some changes with the Australian Industrial Chemical Scheme. It’s currently NICNAS, but it’s now going to be called the Australian Industrial Chemical Scheme. If you’ve been in the register on 1 July you will need an approval in place. [00:48:22] If they’re new chemicals coming in after 1 July they must be notified and assessed whether approval is required. There are some cosmetic issues, so there are some cosmetics I think come across the border from New Zealand. Part of the regulation and part of the approval process is how these goods have been produced and what testing’s gone into place. Under the Australian regime any testing that’s taken place overseas on animals can’t be considered. So if you can’t consider the testing, you can’t get approval. [00:48:53] Of course that’s difficult, because China mandates it as animal testing. So just be mindful of those sort of changes. But if it’s a TGA regulated cosmetic then you don’t need to get a separate approval. The TGA is the Therapeutic Goods Authority.
Chain of responsibility changes. We are making everyone in the chain, as indeed in New Zealand, everyone in the chain of supply, if anything happens in the chain of responsibility before the goods get to the end holder, [00:49:23] whether it’s on the truck that rolls over as it did this morning as I was driving in, luckily I was driving far enough away, but if a truck rolls over or something, and there was a story I think somewhere in Europe where a big bulk tanker on the roads carrying chocolate rolled over and had a delicious mess at the end of it. But again, there’ll be prosecutions out of that. They make everybody in the supply chain, whether it’s the vendor or the loader or the consignor or the customer at the end or whatever it is, [00:49:52] everyone has a responsibility. The levels of the liabilities are going up, and they’ll be extended towards directors and offices too. So just be aware you’ve got nowhere to hide, basically.
FTAs in Australia, we’ve recently done a deal with Peru, PAFTA as it’s known, which is one of the charming concepts. It was the quickest FTA to be negotiated, it took about two weeks to negotiate. Reportedly as many of you would know about Paddington the Bear, Paddington comes from Peru. [00:50:23] I’m not sure whether he was involved in the negotiations, but they went pretty – so it’s part of, if you like, there’s a bit of a pivot at the moment within international trade in our part of the world towards the Americas. So we’ve done a deal with Peru, CPTPP which you’re part of as well includes Mexico. The one who misses out is Bolivia, but we’ll get that through the Pacific Alliance.
Now, the Pacific Alliance is a group of South American countries, basically, or [00:50:53] Central American companies which includes Mexico, it includes Peru, it includes Bolivia, where I’ve actually been, frighteningly enough. They only sent me to Bolivia because DFAT wouldn’t go, they said that their warnings were too high, so they couldn’t send a public servant, but they could send me to go and present. I only found out afterwards. So the Pacific Alliance, I know there’s been some negotiations in Ottawa last week, so they’ve been up doing those negotiations. [00:51:22] And again it’s part of the pivot to that part of the world. So yes, North America is still there, it’s all a bit ‘what is going on up there’, we’re all a bit worried about that, and I was in Washington a month ago talking to a lot of trade lawyers like me, and we all decided we’re going to put our money together and get a subscription to the Psychic Hotline to try and work out what’s happening in the world, because we’ve got no idea half the time.
SAP processing levy on low value transactions, that’s separate to GST, they’re talking about a new processing charge on low value goods. [00:51:53] That’s been parked for this Budget, it might be in the next one coming along. There’s some new espionage legislation being introduced, it’s really a register if you’re representing a foreign interest or a foreign government, to our government. We already have a lobbyist register, this goes beyond that. So it’s not going to be directly – in fact the legislation’s actually pretty awful.
Biosecurity Act which covers food imports into Australia, we’re going to be issuing infringement notices [00:52:22] with more liabilities associated with it. We’ll have a new Imported Food Control Act very shortly in place, the Food Control Act is giving – basically to do with safety, so the step before you and the step after you have got to be able to verify or assure yourself that the goods are safe. We’re getting a new Export Control Act as well, so there’s a lot of stuff taking place in the food area, both in and out. So those of you who are exporting foodstuff to Australia, it also goes to the [00:52:53] country of origin labelling and other types of origin labelling as well, so be mindful of that. There are some changes on country of origin labelling which will formally be in effect as of 1 July. They’re there at the moment, but if you’re bringing foodstuffs into Australia, or any products really, there’s a whole bunch of new regulations, there’s a new standard in place to replace the current standard with New Zealand under the food imports regime.
We’re bringing in anti-bribery law reform, with some stories yesterday out of our press about people being prosecuted for that. What will be interesting is this modern slavery legislation, which will require people to be able to certify the goods are not the product of modern slavery, people producing goods and not being paid a working wage, there are people producing goods who are incarcerated, they’re in jails, and that’s being sold here. There are political prisoners who are producing it as well. So the idea is to crack down on that. It’s going to be applied at a fairly high level to companies [00:53:54] in the supply chain, they’re going to have to certify this. But even so they’re going to say to all their suppliers, all their suppliers of goods or producers, “You have to tell me that these goods don’t come from, aren’t the product of modern slavery”. They’re already seizing stuff in the US under their legislation, there are particular concerns about stuff that’s coming out of North Korea. Goods still do come out of North Korea by the way, and are especially dealt with under our respective Korean free trade agreement. So be aware of that, and start thinking about the supply chain.
There’s going to be changes to our intellectual property laws, which will make it easier to parallel import, so the Australian rights holder of the trademark won’t be able to stop legitimate goods coming in, like they can at the moment, and the New Zealand Customs and Excise Act. Any questions on that stuff before I …
Facilitator: We haven’t had any questions sent through, so we might just keep going.
Andrew Hudson: Well, I’m going to assume that people are still awake. Okay, so some developments in the New Zealand trade agenda, and a lot of it’s a shared experience with Australia. And that’s increasingly I think Australia and New Zealand will work collaboratively, because we have similar agendas, we have similar interests, we have similar issues about getting goods down here and getting products out of here and stuff like that. So if the rest of the world wants to - [00:55:16] we’re engaging with the rest of the world, I think in many cases we can do it in a collaborative sense, which will be the case with the EU free trade agreement perhaps.
So both countries are part of the TPP11. RCEP is the Regional Cooperation Economic Partnership agreement, which is between Australia – well, there’s all the ASEAN nations, plus the countries who have deals with the ASEAN nations, so therefore it drags in India, it drags in China. That’s going really, really slowly. And I think at the moment New Zealand has to make - [00:55:46] sorry, India has to make a decision about whether it really wants a free trade deal. They’re starting to impose large amounts of defensive tariffs in place, so keep in mind.
GST on low value transactions imported into New Zealand, again the discussion paper on that was released in May, be mindful of that, and again talk about it now. If they’re asking for submissions, get submissions in now. Think about how it’s going to affect your business, and try and say – and I think ultimately it’s going to happen, [00:56:17] but can we do it in a non-difficult fashion.
So I’ve given you a whole bunch of stuff there that I’ll go through, but again the effect of the Trump measures, I know New Zealand doesn’t export steel and aluminium, but there are the responsive measures. So if China puts massive additional tariffs on American wine for example, will that American wine then turn up in New Zealand as cheap? The Australian wine industry is worried about it. They say “Well, if the Chinese stop taking American wine, will it all start getting dumped in Australia?”. [00:56:48] I don’t think so, I don’t like a lot of American wine, but there you go. I think our palate is different.
Some New Zealand developments. The trade single window on 1st of July we’ve talked about, the new Customs Act we’ve talked about, we’ve talked about your free trade agreements. New Zealand and China, we’re literally going FTA 2.0, there’s currently discussions going in place about that. Again, be mindful, talk to government, what do you want, what do you need, how are we going to incorporate the stuff you want, [00:57:17] while they’re negotiating as opposed to trying to flip around behind.
I’ve also included – obviously in negotiating with Malaysia, you’ve got current developments, New Zealand/Malaysia, New Zealand/Singapore, New Zealand/Korea deal you have in place. Negotiations are underway with India. We’re also negotiating with India, but that’s largely hit the equivalent of an iceberg. Again, the Indians aren’t entirely sure that they really want services access, and they’re not really fussed about goods, [00:57:47] whereas we want goods, and we already have the services. Some of the Russia, Belarus and Kazakhstan that was on hold, it’s back on again, RCEP. EU FTA we’ve talked about, and we’ve talked about the China FTA update.
I’m just going to briefly, I’m not going to go through the whole thing, can I endorse – the Ministry of Foreign Affairs and Trade issued a trade agenda, released 12 months ago now, but it’s really fresh, it’s worth having a look at, [00:58:16] about the New Zealand trade agenda and what New Zealand needs to do. I wish we did something quite as comprehensive and quite as of high interest. It’s an excellent [unintelligible 00:58:28] and impress people you deal with. So you walk in and “Oh, we’ve been looking at 2030”, and people will be deeply impressed. I know I was. So I won’t take you through all of that stuff, but free trade’s essential, the bottom line is, and that’s a bilateral, that goes both sides of parliament. So as much as there might have been concerns about the current government not supporting the TPP, they have supported it. [00:58:48] And in fact they were really deeply involved in discussing the suspensions that were put into place. So again, we have similar interests, but the need to be flexible. And my experience has been that the New Zealand trade agenda’s more flexible than ours, and it’s being dealt with in quite a sophisticated way. I’m not going to drag you through all of that, significant growth in goods and services.
So again we come back to the WTO is still important, and even more so at a time where [00:59:18] America is talking about making life difficult with WTO, it’s making life even more difficult because it’s blocking the appointment of people to appeal panels on the WTO, so it makes life difficult. Notwithstanding we might have the protectionist moves out of the US or the EU, we’ve still got the good coming out of the free trade agenda, and the liberalising trade agenda, it’s still important and still advances trade. Every economist in the world, even the Americans say it’s good, [00:59:46] it just means that it’s being stopped for purely political reasons. In America the President is delivering what he said he would deliver, whether it’s good or bad. He believes it’s good, that’s why he’s doing it.
So level the playing fields. This gives you an example, it’s just a snapshot here of the steps that your Ministry of Foreign Affairs and Trade, and your trade lawyers are taking to protect your interests at the WTO. And indeed New Zealand’s been a very high user of it, [01:00:16] and a very successful user of it, both to protect its own interests, but also to advance your interests in overseas markets.
Trade policy we’ve talked about there, that’s consistent, that comes out of the trade policy agenda that was put out by the new government, or newish government. And there were some comments made late last year in the manifesto statements and supply confirmation agreements, which is great. We’re a coalition, we’re going to guarantee supply, this is what we’re going to do. We’re going to preserve our right to regulate the purchase of assets in New Zealand, but we’re still going to allow trade to happen. And we’re still not anti-trade. So there we are, I think that’s pretty much it. It is. That’s me. Anymore questions, or have you all had enough by now?
Facilitator: We haven’t had any more through.
Andrew Hudson: Okay.
Facilitator: So we’ve gone a little bit over time, just a few minutes, so I just might wrap it up there, and encourage everyone, if you have not engaged with your professional advisers, please engage about those GST and on low value transactions questions, and make sure that you are in a position to handle that from 1 July. It’s not far away now, [01:01:34] and given the fact that the New Zealand government is looking to talk about the same thing, it would be of benefit to you to get some more information about that and make sure you’re ready.
Andrew Hudson: And just on that too, the ATO and the Border Force have not talked about any moratoriums. So normally they say with new legislation that “We’ll give you a break for six months, we won’t worry about enforcement too much”. They’ve said nothing of that type at this point. So they’re expecting, they’ve had a long lead up, plenty of resources, plenty of engagement, we expect you to be compliant on day one. So yeah, no hiding under rocks, I’m afraid.
Facilitator: Good. And fantastic to see that summary of the enormous amount of work that is being done in the trade area for New Zealand, so thank you for that as well Andrew.
Andrew Hudson: And if I could just encourage you, I know I’ve said it and I say it a lot, but we do it with Australians and New Zealand, we say go and talk to your government representatives, if there are concerns or interests while the deals are being done, now is the time to mention them. And I know government does welcome, does really welcome input, and a lot of the times it does go into the negotiations. There are industry associations representing particular sectors, but that doesn’t mean that should be the – you can go to them, they can facilitate it as well. But please engage, because at the end of the day it’s only as good as the information that goes in.
Facilitator: Excellent. Alright, well, thank you all very much for joining us, and thank you very much to Andrew for an enormous amount of information.
Andrew Hudson: Happy to help.
Facilitator: Alright, have a great day, bye.
Andrew Hudson: Thank you.