Medical Practice Payroll Tax — New South Wales
The position for medical practices in New South Wales (NSW) for FY 2026/2027. · Source: NSW verified against Revenue NSW on 29 August 2026
The position in New South Wales
NSW provides a rebate (not an exemption) on payroll tax attributable to contractor GP payments under relevant contracts, from 4 September 2024. Eligibility is a cliff test: at least 80% of GP services must be bulk-billed in metropolitan Sydney, or at least 70% elsewhere in NSW. At 79% in metro Sydney, the rebate is unavailable in full. Eligibility is assessed across GP services delivered by both contractor and employee GPs; once eligible, the rebate applies only to the payroll tax on contractor GP payments.
What this means for your practice
Calculate your liability in full first (the engine does this), then apply for the rebate on the contractor GP portion. A practice at 78% bulk-billing in metropolitan Sydney is two percentage points from eligibility — this is a real decision point. Moving from 78% to 80% bulk-billing could eliminate the payroll tax on contractor GP payments entirely. Note that the rebate is a post-liability reduction, not a wage exemption — modelling it as an exemption produces a materially different and wrong answer.
Retrospective exposure
A 12-month audit pause ran from 4 September 2023 to 3 September 2024, during which no interest or penalties were charged on unpaid amounts relating to contractor GP payments. The audit pause has ended. Practices with historical non-compliance for periods before 4 September 2024 may have exposure — obtain specialist advice before any voluntary disclosure.
Amnesties and transition
The 12-month audit pause ended on 3 September 2024. There is no ongoing amnesty.
Payroll tax threshold context
New South Wales threshold: $1,200,000 (FY 2026/2027). Deemed wages plus employed staff wages are tested against this threshold.
Standing note: This is a self-assessment worksheet for discussion with a registered tax agent, not tax advice or a determination. The medical practice payroll tax area is contested, with live retrospective assessments. Obtain a specialist opinion before any voluntary disclosure.
How a NSW medical practice creates deemed wages
A NSW medical practice creates deemed wages when it bills Medicare or the patient in its own name and then passes the balance to a practitioner under a Service Facility Agreement. What the practice keeps is the service fee; what it passes on is the deemed wage. The practitioner's ABN does not change that characterisation.
The amount is worked out practitioner by practitioner. A practice remitting to eight contractor GPs therefore has eight separate amounts, and it is their combined total, added to employed staff wages, that meets the $1,200,000 threshold.
Satisfying the NSW bulk-billing test
NSW's rebate is conditional on the practice's bulk-billing rate: 80% of GP services in metropolitan Sydney, 70% elsewhere. Critically, the rate is measured on services delivered by contractor and employee GPs together, so a practice cannot lift its proportion by pointing only to a fully bulk-billed employee cohort.
Because the test is a cliff, the proportion should be measured the way Revenue NSW measures it — by service, across the whole GP cohort. A metropolitan practice at 79% is not nearly eligible; it is ineligible.
Which practitioners the NSW rebate reaches
The rebate touches only the payroll tax attributable to contractor GP payments. Employee GP wages, non-GP medical specialists, allied health practitioners and hospital-employed doctors are all outside it. A practice with a mixed clinical team must therefore keep the contractor GP cohort separate from every other practitioner group in its records.
Where GPs and specialists are both engaged, the 80%/70% test is still run on GP services alone. The specialist cohort's payments stay fully taxable and are not helped by the practice's GP bulk-billing rate.
Records that support a NSW rebate claim
A NSW position rests on three things: the Service Facility Agreements, the billing data from which the bulk-billing proportion is derived (with Sydney separated from the rest of the state), and the group structure naming the Designated Group Employer.
Because the rebate is claimed rather than applied automatically, a reconciliation isolating the contractor GP portion is also needed. If all practitioner payments sit in one ledger line, the practice cannot demonstrate the split a claim requires, however sound its underlying position.
The NSW practices most exposed
A NSW practice with a large contractor GP cohort and a bulk-billing rate near the threshold carries the most risk. At 78% in metropolitan Sydney the full deemed wage base is taxed with no rebate, and two percentage points of bulk-billing move the outcome materially.
Multi-site and corporate GP groups face a second exposure: once the entities are grouped, only the Designated Group Employer holds the threshold, and every other site pays 5.45% from the first dollar.
Errors that recur in NSW positions
Two mistakes appear again and again. The first is treating the rebate as an exemption — reducing wages instead of reducing tax. The second is reading the bulk-billing test as applying to the whole practice rather than to GP services. Each produces a materially wrong figure.
A third is leaving the Designated Group Employer nomination unmade, which forfeits the threshold for every group member except the one the revenue office selects.
The two NSW GP cohorts a practice must keep apart
A NSW practice's payroll rarely contains one kind of doctor. Contractor GPs billing through the practice, salaried GPs on its own payroll, GP registrars and non-GP specialists may all appear, and the rebate does not treat them alike. Only the payroll tax on contractor GP payments can be rebated; employed GP wages, specialist payments and allied health payments carry their full liability.
The bulk-billing test, however, counts services from contractor and employee GPs together. That mismatch — a test measured on a wider group than the rebate reaches — is why a practice has to report its GP service data and its payroll separately. A practice that cannot split the two can neither show that it satisfies the test nor support the claim that follows.
How a NSW practice applies the rebate in its accounts
The rebate reduces payroll tax, not wages. In practice a NSW practice assesses its liability on the full deemed wage base — contractor GP remittances included — pays on that basis, and then claims the rebate on the portion of tax attributable to contractor GP payments. The wage base itself is unchanged.
The distinction matters for planning. A practice that models the rebate as an exemption will understate both its wage base and, in the periods before the claim is accepted, its cash obligation. The right mental model is a full assessment followed by a targeted credit, and the records should show both halves.
The order in which a NSW practice should settle its position
Five steps, in sequence. Confirm the billing model. Work out the deemed wage for each practitioner. Measure the bulk-billing rate across GP services, with metropolitan Sydney separated from the rest of the state. Test that rate against the 80%/70% cliff. Then, only where the cliff is cleared, isolate the payroll tax on contractor GP payments for the claim.
Each step depends on the one before it, and the fourth is where practices most often fail — not because the rate is low, but because it was measured on the wrong base. A practice that runs the five steps in its records can support a claim on review; one that reconstructs them at year end usually cannot.
A worked NSW medical scenario
Take a NSW practice with $500,000 of employed staff wages and $1,000,000 remitted to contractor GPs, giving $1,500,000 of taxable wages. After the $1,200,000 threshold, $300,000 is taxed at 5.45% — a base liability of $16,350 before any rebate. Whether the rebate reduces that liability depends entirely on the bulk-billing proportion, measured across all GP services.
If the practice is in regional NSW and bulk-bills 70% or more of its GP services, it clears the regional test and the rebate applies to the payroll tax on the contractor GP portion. At 68% it clears nothing, and the full liability stands. The gap between 68% and 70% is the difference between a rebate and none, which is why the proportion should be measured precisely rather than estimated.
Reviewed by eHealth Systems Pty Ltd