Key Takeaways
- Payment Structure Impact: Payment arrangements where patient revenue is not directly paid to practitioners may result in such payments being deemed as wages for payroll tax. This may include scenarios involving shared bank accounts in the names of the practitioner(s).
- Case-Specific Evaluation: The Queensland Revenue Office will continue to evaluate practitioner payments and arrangements between medical centres and practitioners on a case-by-case basis. Medical centres should review agreements to ensure compliance, especially where they are using or considering using intermediary bank accounts.
In our previous article we discussed the revised Public Ruling issued by the Queensland Revenue Office (QRO) in September 2023. This clarified that if assigned Medicare benefits and any out-of-pocket patient fees (patient revenue) are paid directly to a practitioner as a sole trader, these will not be deemed “wages” for payroll tax purposes.
The QRO has since further revised the Public Ruling, re-affirming the position that patient revenue that is not paid directly to a practitioner may be deemed wages, and providing further commentary in a new example 14.
If a banking arrangement involves an initial payment by the patient to a bank account not belonging to the practitioner, followed by subsequent payments by the medical centre or a third party to the practitioner, then these subsequent payments may be deemed wages. For example, where there is a shared bank account in the name of the practitioners who work at the practice, into which all patient revenue is paid, and from which the practitioner’s share of the patient revenue is paid out to each practitioner.
It is important for the medical centre to consider whether, under their current arrangements, the practitioner is able to access patient revenue paid to them directly or such access is subject to and conditional upon any approval or direction of the medical centre. The revised Public Ruling states that the QRO will continue to assess such payments, and arrangements between practitioners and medical centres, on a case by case basis.
We recommend that businesses that operate a medical centre consider the terms of their current Agreements and arrangements with practitioners, particularly where they have considered or are using an intermediary bank account. Please contact Director, Craig Hong to discuss further on email or 07 3220 1144.
The information in this blog is intended only to provide a general overview and has not been prepared with a view to any particular situation or set of circumstances. It is not intended to be comprehensive nor does it constitute legal advice. While we attempt to ensure the information is current and accurate we do not guarantee its currency and accuracy. You should seek legal or other professional advice before acting or relying on any of the information in this blog as it may not be appropriate for your individual circumstances.