The ATO has finally released GST Ruling GSTR 2011/1. In effect it raises the spectre of the operator having to pay GST on the value of the DMF book at the time of sale of the village. So a $30 million DMF book would have a $3 million GST hit. The Not For Profits at present will be exempt but are concerned it will eventually flow to them too. The ATO has also hit tax input credits, meaning recalculation of GST on interest in particular in the development phase. For more information contact the Retirement Villages Association.