The Australian Tax Office (“ATO”) has released a ruling regarding the use of the PDF version of the monthly Vehicle Activity Apportionment Report (“The Report”) generated by Prism using data recorded by Geotab Go7 and Go9 vehicle tracking devices.
The ruling states that this report can be used for record-keeping in relation to Fuel Tax Credits (“FTC”). It may also assist clients in estimating their fuel apportionment when combined with other business information about the vehicle and fuel usage.
As with other Class Rulings, the ATO's issuance of this ruling doesn't mean they endorse the Prism platform or the Geotab devices or that the results produced will be accepted as correct without supporting evidence.
We recommend that users seek professional tax advice in relation to their FTC claims and follow the guidelines published by the ATO regarding appropriate methods of calculation and record keeping.
Conditions of applicability
A Class Ruling is a public ruling that provides a detailed interpretation of how a particular provision in the tax law applies to a specific arrangement or scheme for defined set ('the Class') of entities. In this case the ruling applies to businesses that meet the following criteria:
Registered for good and services tax
Use Geotab G07 or G09 telematics devices to capture vehicle activity data
Generates and uses the Report for measuring the kilometres travelled, idle time and auxiliary equipment engagement time (such as when the power take-off (PTO) is engaged) as part of calculating the extent of your FTC entitlement.
Although Prism integrates with, and can perform analysis of vehicle data, for devices provided by a number of telematic companies, this Ruling is limited to users of Geotab Go7 and Go9 devices only.
For users who meet the criteria that define the applicable class of entities, the following conditions also apply:
The ruling applies to taxable fuel acquired on or after 1 January 2023 to 30 June 2024.
The reports must be retained for at least 5 years after the completion of the transactions or acts to which they relate.
Supporting evidence and record keeping
The Report provides detailed information about vehicle usage, including distances traveled on and off-road, idle times, and this information forms part of the formula to determine the extent of the taxable fuel used in the vehicle to be apportioned for fuel tax credit purposes and satisfies record-keeping requirements for FTC claims.
However, it is not the only record that is required and other documentation, like fuel acquisition records and data input information, are necessary to comprehensively support FTC claims. Other records may include:
data input information reports and source data records
reports showing accuracy of fuel consumption rates used for vehicles and other inputs
fuel acquisition records (such as tax invoices)
confirmation of location and time (such as driver job sheet)
documentation to verify that the environmental criteria has been satisfied
documentation on the use of fuel along with supporting evidence demonstrating the accuracy of information from the Report and calculations of credits and this can include
total litres after information from other source documentation has been incorporated
litres based on the categorisation of travel on public roads and off public roads
litres used in auxiliary equipment (where applicable)
litres used while the vehicle is idling off-road based on time and the categorisation of off-road use
evidence of other assurance or process checks that have been undertaken to ensure that the amounts included in the Report are accurate.
We do not provide tax advice so we recommend that all Prism users seek advice from a registered tax agent to assist in configuring and supporting your FTC claims.
The Report is produced following a sequence of actions performed by both Prism and Geotab systems. While GPS tracking technology is generally highly reliable and detailed, it is important to understand how the systems work together as you would be expected to have performed validation of the data to ensure your vehicle activity is being accurately captured and represented in the Report.
Here’s what you need to know:
The Prism team don’t sell, install or control the Geotab devices. As a user, it is your responsibility to ensure the device is installed in accordance with Geotab’s installation guides by a qualified installer.
The data Prism sources is from the Geotab API not the device directly. So it is after Geotab has applied it’s own cleaning and filtering methods including the Curve Logging Algorithm.
Prism accesses Geotab data for Devices, Trips, Positions and Diagnostics. Some data items, such as PTO events, may only be available with the certain vehicles and device configurations.
Prism provides options to selectively include or exclude trips that allow you to tailor the process to ensure your vehicle activity is accurately reflected. More information about these options is available here.
To determine vehicle use on Public and Non-Public roads, Prism compares each GPS position to a continuously maintained database of spatial features covering Australia and provides tools that allow you to visualise these locations so you can see the results. We encourage all users to review these items regularly and inform us of any potential errors so we can adjust them if needed.
Should you need any further technical information about how Prism works with Geotab, or wish to raise an issue for investigation, please contact our team at firstname.lastname@example.org
Controls and governance
Our primary objective is to ensure that Prism provides an accurate analysis of your vehicle activity. We have and continue to undertake activities to measure the accuracy of our results and identify and resolve any technical or data issues that may occur.
However, Prism is dependent on the data provided by your telematics devices and the limitations associated with them with regards to positional accuracy and movement tracking.
In developing this solution using Geotab devices, we implement the following actions to ensure the system meets our intended quality and accuracy criteria:
Technical controls within the integration with Geotab to check that trip records provided to Prism match those visible in Geotab and ensure that posittion records are within the Geotab-defined trips, where trips, positions and ignition events are evaluated together.
Platform features to visualise vehicle activity and location classifications for the the entire data set used to produce the Report.
Vehicle specification lookup against the National Heavy Vehicle Regulator API to validate descriptions (for Heavy Vehicles only).
Fixed processing rules within Prism to avoid inadvertent Non-Public road classification of positions by requiring at least 4 consecutive off-road points to confirm the classification (other than at the start and end of a trip).
Continuous improvement of spatial data, including source updates and evaluation of feedback from users and qualified external parties.
Regular internal review of locations with the highest Non-Public road usage across all Prism users to focus analysis and confirmation activities.
Regular checks of aggregate vehicle activity across all Prism users to identify data completeness or quality issues.
Providing users with full access to all vehicle data used or produced by Prism for independent analysis and full transparency.
Ongoing education of users regarding the capabilities and limitations of Prism and their responsibility when using the platform.
Getting your FTC claims right can be complex but you can significantly reduce the risk and overheads involved by using technology and ensuring you have the right technical and administrative processes in place to support it.
To recap the main points:
The Class Ruling establishes the Report as a valid record for FTC claims, but it isn’t the only record you need to use.
The Ruling only applies to users of Geotab Go7 and Go9 devices.
Refer to the ATO’s guides on record keeping to ensure you have the right ones in place.
Get professional tax advice to ensure you have the right approach and haven’t missed anything important.
Understand the limitations of the technology you use and your responsibilities in using it for FTC.
Contact our team if you need more information or help using Prism.