Why suite owners are reading these rulings
Victoria, New South Wales and Queensland have each published a ruling on how the “relevant contract” (contractor) provisions of their payroll tax law apply to medical centres and the practitioners who work from them. Depending on the facts, payments under an arrangement between a medical centre and a practitioner can be treated as wages for payroll tax.
This page summarises what each ruling covers and links to it. It does not tell you whether payroll tax applies to your suite. That depends on the substance of your arrangements, and only your own adviser can assess it.
Victoria
SRO public ruling PTA-041, Relevant contracts – medical centres
- Issued
- 11 August 2023. The SRO page was last updated on 22 June 2026.
- Legislation
- The relevant contract provisions of the Payroll Tax Act 2007 (Vic).
- Case law discussed
- Commissioner of State Revenue v The Optical Superstore Pty Ltd [2019] VSCA 197.
- Worth noting
- The SRO looks at the substance of an arrangement, not the label on it. The ruling also notes that rulings do not have the force of law.
New South Wales
Revenue NSW ruling PTA 041, Payroll Tax Act – Relevant Contracts – Medical Centres
- Issued
- 11 August 2023, effective from 1 July 2018. Status: current.
- Legislation
- The contractor provisions in Division 7 of Part 3 of the Payroll Tax Act 2007 (NSW).
- Case law discussed
- Thomas and Naaz Pty Ltd v Chief Commissioner of State Revenue [2021] NSWCATAD 259, upheld on appeal in [2022] NSWCATAP 220, and The Optical Superstore case.
Queensland
QRO public ruling PTAQ000.6, Relevant contracts – medical centres
- Current version
- PTAQ000.6.5, issued 3 March 2025.
- Legislation
- The relevant contract provisions in the Payroll Tax Act 1971 (Qld).
- Scope
- Medical centres, including dental clinics, physiotherapy practices, radiology centres and similar healthcare providers that engage practitioners.
What to take to your adviser
- Each practitioner’s current agreement, and any earlier versions, with their start and end dates.
- What each practitioner pays you, and on what basis: per session, a percentage of billings, or both.
- What the suite provides: rooms, reception, booking, billing services, equipment, consumables.
- Who collects patient fees, and how money flows between patients, practitioners and the suite.
- How many days each practitioner works from your rooms, and whether they practise elsewhere.
Where SuiteBook fits
SuiteBook is a billing tool. It keeps each specialist’s arrangement dated, with its document type, rooms and fees, records every session charged under it, and locks each finalised month with an audit log. That makes it easier to give your adviser an accurate picture of what was charged and when. It does not decide whether an arrangement is a relevant contract, whether an exemption applies, or whether any amount is wages. See our compliance stance.