Six state payroll tax rules and one Commonwealth incentive, all keyed to bulk billing, none aligned
Every jurisdiction built a payroll tax concession keyed to bulk billing, and set it differently — 80 per cent of wages, 80 per cent of services, proportionally, outright, or by threshold. The Commonwealth requires 100 per cent. Nobody chose this; it is what happens when two tiers pick the same lever.
Steps this would change
Rationale
This is the seventh instance in this database of a national activity meeting divided jurisdictions — and it is different from the other six in an instructive way.
The previous six were absences: a national scheme that Queensland or Victoria had not joined, a clearance that did not travel, a credential re-verified at every hospital. This one is the opposite. Every jurisdiction did act, quickly and in the same policy direction, and the incompatibility is a product of six governments independently doing the right thing.
Following rulings bringing contractor GP payments into the payroll tax base, each built a concession keyed to bulk billing:
| Jurisdiction | Test |
|---|---|
| South Australia | 80 per cent exemption on GP wages where the practice bulk bills |
| New South Wales | rebate where at least 80 per cent of GP services are bulk billed, metropolitan Sydney qualifier |
| Victoria | proportional exemption based on bulk billed income share |
| ACT | exemption for bulk billed services outright |
| Northern Territory | no medical-specific rule; general threshold raised to $2.5 million |
| Western Australia | effectively by threshold, $1 million |
And the Commonwealth's practice incentive requires 100 per cent.
These tests do not merely differ in level. They differ in unit: a share of wages, a share of services, a proportion of income. A practice cannot compute one answer and apply it in two places. A group operating across the Murray runs two different calculations on the same billing behaviour.
What could change. Not uniform rates — payroll tax is a state tax and states are entitled to set their own. A common definition and measurement basis for "bulk billing" across the concessions, so that a practice establishes the fact once and each government applies its own rate to it. That is the same distinction this site draws in Verify credentials nationally once; keep the scope of practice decision local: verify once, decide separately.
Who acts: state and territory revenue offices collectively, with the Commonwealth, most plausibly through the mechanism that already coordinates tax administration across jurisdictions.
What is being traded away
This is a coordination proposal in the hardest possible domain. Payroll tax is one of the last substantial state tax bases and jurisdictions guard their autonomy over it closely. Asking six revenue offices to adopt a common measurement basis defined partly by reference to a Commonwealth health program is asking them to cede definitional control over their own tax to another government. The history of tax harmonisation in Australia suggests this takes decades when it happens at all.
A common definition would advantage whoever writes it. If the measurement basis follows the Commonwealth's 100 per cent formulation, states that deliberately set an 80 per cent test to reach mixed-billing practices would find their policy narrowed. Alignment is not neutral; it means someone's threshold wins.
The concessions are recent, contested and may not last. Several were built as amnesties or transitional measures and their permanence is not settled. Harmonising a set of arrangements that individual states may withdraw or rewrite is building on ground that is still moving.
And this database should be honest that the underlying problem is not definitional. The reason any of this exists is that payroll tax was applied to contractor GPs in a way the sector did not expect, and the concessions are patches. A cleaner answer would be to resolve the contractor question itself rather than to harmonise the exemptions from it — which is a tax policy argument well outside what a process database can adjudicate.
Precedent
The concessions themselves are the precedent: every jurisdiction has already accepted that bulk billing is the right thing to key relief to. What has not happened is any of them agreeing on how to measure it.
Sources
- RevenueSA Revenue Ruling PTASA004; Revenue NSW Bulk Billing Support Initiative from 4 September 2024; Victorian exemption from 1 July 2025; ACT Revenue Office designated medical practices exemption from 1 July 2025; NT threshold $2.5 million from 1 July 2025; WA threshold $1 million
- Services Australia, Bulk Billing Practice Incentive Program: 100 per cent bulk billing requirement