Who Is the Seller of Record in Australia, and Why the ATO Cares (2026)

“Seller of record” is a marketplace and payments term. The ATO’s law never uses it. For GST the question is who the supplier of the sale is, and the GST Act answers it with four roles: the merchant, the electronic distribution platform operator, the redeliverer and the importer. Being named on the listing decides none of them by itself. For goods of A$1,000 or less shipped from overseas through a marketplace, the platform is deemed the supplier and the sale leaves your turnover. For goods already in Australia when sold, goods over A$1,000, or sales through your own website, you are the supplier whatever the listing says.

That matters because one business charges GST on a sale, never two. Answer the supplier question with the listing name and you either double-tax your customer, or assume the platform has it covered when it doesn’t and register late. Below: what the term means, the supplier test, when you’re the supplier regardless, the importer and “merchant of record” questions, and why the ATO cares enough to collect the data from the platforms directly.

(General information for FY 2026–27, not tax advice for your circumstances. The platform rules were read on 9 October 2026 from the ATO legal database: GST Act section 84-81 and Law Companion Ruling 2018/2. The importer test, turnover rules and warehousing rule are the ATO’s published guidance as verified for our earlier articles. The A$75,000 threshold is not indexed and may change.)

1. What does “seller of record” mean in Australia, and why doesn’t the ATO use the phrase?

On a marketplace, the seller of record is the business named as the seller on the listing, the order and the customer’s receipt. On a payments or checkout service, the “merchant of record” is the business that legally sells to the customer and takes the payment. Both are commercial labels. Neither appears in the GST law.

The ATO asks a narrower question: for this sale, which entity is treated as the supplier? That decides who must be registered, who collects the GST, whose turnover the sale counts in, and who issues the tax invoice or receipt. The GST Act gives four possible answers:

Role	Who	When they are the supplier for GST
Merchant	The business selling the goods	The default: every sale where no deeming rule moves it
Platform operator	The operator of an electronic distribution platform (EDP), a marketplace	Goods of A$1,000 or less shipped from overseas through the platform to a consumer
Redeliverer	A forwarding or shopping service the consumer uses to get offshore goods into Australia	Deemed the supplier for those goods
Importer	Whoever brings goods over the border for their own purposes	Not a supplier of the sale, but the only party who can claim the import GST credit

A seller can be the seller of record on every listing it has and still be the GST supplier on some of those sales and not others. Sections 2 and 3 show the line.

2. The GST supplier test: when the platform, not you, is the supplier

Section 84-81(3) of the GST Act applies the platform rule to goods: “Section 84-55 applies to a supply as if it were an inbound intangible consumer supply if: (a) the supply is made through an electronic distribution platform; and (b) the supply is an offshore supply of low value goods.” The note under it says what that means: “Section 84-55 treats the operator of an electronic distribution platform as the supplier of supplies made through the platform.”

The Commissioner’s ruling, LCR 2018/2, turns that into four steps. “If each of the four steps set out in this Ruling are satisfied, an EDP operator will be responsible for GST on a supply made through their platform. If the EDP operator is responsible for GST, the merchant will not be responsible for GST.”

Step 1: is the service an EDP? An EDP “includes (but is not limited to) a website, internet portal, gateway, store or marketplace” that lets businesses make supplies available to end-users and is delivered by electronic communication. A service that lets buyers make offers or lets merchants accept orders qualifies. Three things are expressly not an EDP on their own: a carriage service, a payment system or payment processing, and face-value vouchers. And the one overseas sellers trip on most: “A service is not an EDP if it only builds or maintains the infrastructure behind a service that makes supplies available to end-users. For example, a service provider who builds a website that includes a shopping cart functionality (for the operator of a website) is not itself an EDP. However, the operator of the website, which is the recipient of those services, could be an EDP.” Your own store is not a platform; a marketplace is.

Step 2: is the supply one the rules cover? For goods: an offshore supply of low value goods, that is, a customs value of A$1,000 or less, shipped from outside Australia, to a consumer.

Step 3: does the exclusion apply? The merchant takes the liability back only if all of the following hold: the operator does not authorise the charge to the customer; does not authorise delivery; does not set, directly or indirectly, any of the terms and conditions; a document issued to the customer identifies the merchant as the supplier; and “the merchant and the EDP operator have agreed in writing that the merchant is the entity liable for paying the GST”. Authorising the charge is wide: communicating the liability to pay, or influencing whether or when the customer pays, “may be done by initiating the process through which the recipient is charged”, and the operator need not collect the money itself. On an ordinary marketplace checkout, the exclusion does not apply.

Step 4: more than one platform? The operators may agree in writing which is the supplier. Absent agreement, “the operator responsible for the GST is the first of the EDP operators to receive or authorise the charging of any of the consideration for the supply”.

The consequence is the one that moves money: “If the EDP operator is responsible for GST, these sales don’t count towards your GST turnover when calculating if you need to register.” Our article on whether Amazon collects GST for you walks through this on one platform’s two models.

3. When you are the supplier regardless of what the listing says

The deeming rule is narrow. Step outside it and you are the supplier, whoever’s name is on the listing. The ruling puts the first two cases in one sentence: “the EDP rules do not apply if the supply is connected with Australia because the goods are sourced within Australia, or the merchant is the importer.”

Four situations:

The goods are already in Australia when sold. Stock in a fulfilment centre or 3PL is not an offshore supply of low value goods. The ATO’s guidance for a non-resident who “imports goods and warehouses them in Australia prior to selling them online, directly or through an electronic distribution platform” is that it “will have a GST obligation for the goods sold because the goods are located in Australia”, and the platform “is not treated as the supplier”. That means standard registration on an ABN; simplified registration is unavailable once goods are warehoused here. The ABN comes through the entitlement for overseas businesses making supplies connected with Australia.
The consignment is over A$1,000. Then it isn’t a low value good at all. GST, duty and clearance are charged to the importer at the border, “even if the supplier incorrectly charged GST on the sale”. On a direct-shipped consumer order the consumer is normally that importer.
You sell through your own website. A shopping-cart platform is not an EDP (step 1), so every sale on your own store is yours and all of it counts toward your turnover. Our Shopify GST article covers that channel.
You are the importer. If you bring the goods in yourself before the sale, the platform rules don’t apply.

One role to name and set aside: the redeliverer. Where a consumer buys goods offshore and uses a forwarding or personal-shopper service to bring them in, section 84-81(4) deems that service the supplier, and with several redeliverers, the first to deal with the consumer. It is the consumer’s arrangement, not the seller’s, and it does not change who the supplier is on a sale the seller ships.

4. The importer of record is a different question again, and so is “merchant of record”

Importer of record is a customs role, not a GST supplier role. The ATO’s test has two parts: you are the importer if “you have caused the goods to be brought to Australia for your own purposes” and “you or your agent have completed the customs formalities or would be responsible for the customs formalities”. It matters for one reason above all: only the importer can claim the GST paid at the border as a credit.

For a seller who bulk-ships stock into an Australian fulfilment centre, that is the seller, named on the import declaration through its broker, and the import GST on each consignment is creditable on a standard registration. For a direct-shipped consumer parcel over A$1,000, it is normally the consumer, who pays at the border and claims nothing. The trap is a freight forwarder named as owner in its own right on the declaration: then “no entity can claim a GST credit”, because the forwarder didn’t cause the goods to come for its own purposes and the seller isn’t on the document. Our article on who gets the import GST back goes through the evidence and the fixes.

“Merchant of record” is the third label, and it does change the supplier. A checkout service that becomes the merchant of record sells to the customer in its own name; the checkout says so. Your supply is then to that service, not to the Australian consumer. For GST that sale is no longer yours to the consumer, and your connected-sales turnover changes accordingly. What you have instead is a contract with the service, and its terms decide what you’re paid and what it charges.

5. Why the ATO cares: one supplier per sale, turnover, and the platform reports

Because the system is built on one answer per sale. “Only one business is required to charge GST on a sale”: if the platform is responsible, the merchant isn’t; if the platform or merchant is, the redeliverer isn’t. Get the answer wrong in one direction and the customer pays GST twice. Get it wrong in the other and nobody collects, which the ATO can now see.

Three reasons the answer is enforced rather than assumed:

Turnover follows the supplier role. The A$75,000 test counts the sales you are the supplier of, not the sales with your name on the listing. Platform-responsible sales are out; warehoused and own-site sales are in.
One charge per sale. A seller who adds GST to a marketplace price the platform already taxes has overcharged; one who assumes the platform covers fulfilment-centre stock has under-collected and is registered late, with the consequences in our late registration article.
The platforms report you. Under the sharing economy reporting regime, every electronic distribution platform has reported its sellers’ transactions to the ATO twice a year since 1 July 2024. The listing-level data is already on the ATO’s side.

Jonas runs a German company selling kitchen tools to Australian consumers through three channels in one year. He is seller of record on every listing.

Channel	Sales	GST supplier	In Jonas’s turnover?
A. Marketplace, shipped direct from Germany, each parcel under A$1,000	A$60,000	The platform: an EDP, offshore low value goods, it authorises charge and delivery, no written agreement	No
B. Same marketplace, from stock in its Sydney fulfilment centre	A$50,000	Jonas: goods in Australia when sold; the platform is not treated as supplier	Yes
C. His own website, shipped direct from Germany	A$40,000	Jonas: a shopping cart is not an EDP	Yes
Turnover for the A$75,000 test			A$90,000

Jonas must register: standard registration on an ABN, because channel B warehouses goods here. He remits GST of A$8,182 on B and C combined; the platform remits on A. He is the importer of the bulk consignments into the Sydney centre and claims that import GST. If he later moved channel C onto a merchant-of-record checkout, C would leave his turnover and B alone, at A$50,000, would sit under the line, though he might stay registered to keep the import credits.

Same seller of record on every listing. Three different answers.

Where it’s worth getting help

If you sell through one channel, the four steps give a clean answer and most sellers can apply them: marketplace direct-ship means the platform; anything warehoused here or on your own site means you.

The judgment calls are these:

Several channels at once. Turnover is the sum of the sales you are the supplier of, across all of them, on the current and projected tests, and it moves the day stock lands in a fulfilment centre.
The bulk consignment. Who is named as importer on the declaration decides whether the import GST is ever recovered.
Merchant-of-record and platform contracts. Which entity sells to the consumer, and whether any written agreement shifts GST liability back to you, is in the terms, not the listing.
Mixed baskets. Orders that combine items over the A$1,000 line, or platform and warehoused items, need the checkout to know which rule applies to which line.

That’s the difference between doing it and doing it right the first time: the seller who registered on day one for the right channels, versus the one who charged GST twice on one and nothing on another, and found out from the platform’s report.

If you’d like that looked at properly, our initial assessment form scopes it in about twelve questions, including each channel, where the stock sits, and who clears it, without needing a meeting.

FY 2026–27. General information, not tax advice for your circumstances. The platform and importer rules are the ATO’s published settings at 9 October 2026; “seller of record” and “merchant of record” are commercial terms used by platforms and payment services, not by the ATO. The A$75,000 GST registration turnover threshold is not indexed and may change; confirm the current figure.