Thomas and Naaz for locum doctors

Thomas and Naaz Pty Ltd v Chief Commissioner of State Revenue concerns medical-centre contractor arrangements and payroll tax. The litigation includes the NCAT Appeal Panel decision [2022] NSWCATAP 220 and the NSW Court of Appeal decision [2023] NSWCA 40. Ask your adviser to explain the relevant-contract provisions and how the facts of your proposed engagement compare.

State rules and GP relief need separate consideration. For 2025-26, the state revenue guidance records GP relief in NSW, Victoria, Queensland, South Australia and the ACT, with different conditions. Western Australia has not adopted the harmonised relevant-contract deeming regime. Check the current state revenue guidance and seek advice on your contract rather than treating a state or profession label as a decision about liability.

If a workplace proposes a new contract or a higher service fee, ask for the reason and calculation in writing. Request a comparison between the existing arrangement and the proposed one using the same billings. That makes it easier to see which assumptions changed and which deductions affect the amount payable to you.

Ask who will issue patient accounts, receive payments, reconcile receipts and provide statements. Confirm how refunds, unpaid accounts, cancellations and adjustments are handled. Take the contract and worked example to your adviser before accepting an explanation that payroll tax requires a particular fee or payment model.

From 1 July 2025, Victoria exempts GP wages from payroll tax to the extent they relate to fully-funded, bulk-billed items. This is proportional relief, not a blanket exemption for every GP payment. Read the Victorian State Revenue Office medical-industry guidance and ask your adviser which conditions matter for the proposed arrangement.

NSW uses a GP rebate scheme, while Queensland, South Australia and the ACT have their own GP exemptions with different conditions. A Victorian example does not establish the result elsewhere. If you work across states, give your adviser the locations and dates for each engagement and ask which revenue office guidance to use.

Ask the state revenue office about the rules for your profession and the work in the contract. Do not assume the GP relief described above extends to specialist, dental or allied health work. Equally, a general discussion of contractor arrangements does not establish that a particular payment is taxable.

Describe your actual duties when seeking advice. If an engagement combines different services, bring the fee schedule and explain how each service is billed and paid. Keep any written explanation from the workplace with the contract so your adviser can review the assumptions behind the offer.

• Which state is the workplace in, and what dates does the contract cover?
• Is the payment a fixed fee, a percentage of billings or a combination?
• Who bills the patient and receives the payment?
• If Medicare benefits are involved, who is the payee?
• If a service fee applies, what does it cover and is GST included?
• What does the agreement say about super, and what should your adviser review?

Request a worked example using the same assumptions as the quoted rate. Keep the gross receipts, each deduction and the amount payable to you visible in that example. Read the direct billing guide for recording the agreed arrangement in Sessional.