Target Market Determination – GST Loans

This Target Market Determination (TMD) has been prepared in accordance with the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 (Cth) and associated Regulations. TMDs are designed to assist issuers to ensure that the financial products they issue are likely to be consistent with the likely objective, financial situation and needs of the consumers for whom they are intended (the target market) and to assist distributors to ensure that financial products are distributed to the target market.

Note: This TMD has been prepared on a voluntary basis consistent with good product governance under RG 274. The GST Loan product is likely not a “financial product” for the purposes of Chapter 7 of the Corporations Act 2001 (Cth) given the commercial/business purpose and borrower profile. This TMD is maintained as a matter of prudent product governance.

This TMD is general in nature and should not be treated as a full summary of the Product’s terms and conditions or be construed as financial advice. Consumers should obtain independent advice prior to acquiring the product to ensure that it is appropriate for their objectives, financial situation and needs.

Product

Short term GST funding loan for the GST component payable on the purchase of commercial property.

Product Issuer

This product is issued by Property Credit Pty Ltd ACN 638 329 674, Australian Credit Licence Number 528878 (Property Credit)

Date of TMD

29 September 2026

Target Market Determination

Description of target market, including likely objectives, financial situations and needs

This product has been assessed as meeting the likely objectives, financial situation and needs of consumers who:

• Meet Property Credit’s eligibility criteria (including but not limited to):
  • A company, trustee, or individual (including sole trader) borrower
  • If an individual, are over the age of 18 years of age and are borrowing for a business or commercial purpose
  • Hold a valid Australian Business Number (ABN) or Australian Company Number (ACN)
  • Are registered for GST under the A New Tax System (Goods and Services Tax) Act 1999 (Cth)
  • Are the purchaser (or intending purchaser) of commercial property in Australia on which GST is payable at settlement
  • Are entitled to claim an input tax credit for the GST paid on the property acquisition
• Require short-term funding to cover the GST component (typically 1/11th of the purchase price) payable at settlement on a commercial property purchase
• Have entered into, or are about to enter into, a contract of sale for the purchase of commercial property
• Have capacity to repay the outstanding loan balance in full from the ATO GST refund, or from other sources if the refund is delayed, reduced, or disallowed
• Can complete the application form online

Description of product including key attributes*

This product’s key attributes include the following:

• Loan Advance is subject to lending criteria, the GST amount payable on the commercial property transaction, and verification of the borrower’s entitlement to an input tax credit
• Maximum Loan to Value Ratio (LVR) of 80%
• Minimum Facility Amount of $50,000
• Maximum Facility Amount of $1,000,000
• Minimum Loan Term of 1 month, aligned with BAS cycle
• Maximum Loan Term of 3 months, aligned with BAS cycle
• Security may be required which may include a caveat or mortgage over the commercial property being purchased, and/or an assignment or charge over the borrower’s GST refund entitlement.
• Loan repayments are payable until the earlier of:
  • Receipt of the ATO GST refund; or
  • 3 months from the date of drawdown
• Fees and charges include establishment fees, monthly fees and late fees
• Other fees and charges may apply as set out in the loan agreement
• Product features:
  • Online application process
  • Digital Verification Service capability for verification of identity requirements
  • Customer portal
  • Customer support including phone, email and chat capabilities
  • Electronic contract distribution and signature capability

* The Loan Term, Facility Amount, fees and charges and Loan to Value ratio will vary depending on the consumer’s circumstances.

Class of customers for whom this product is not suitable

This product may not be suitable for consumers who:

• Do not meet our eligibility criteria
• Are not registered for GST or are not entitled to claim an input tax credit for the GST on the property acquisition
• Are purchasing residential property (which is generally GST-free or subject to the margin scheme)
• Are purchasing property as a going concern (where no GST is payable)
• Do not have the ability to provide the required security
• Do not intend to use the loan solely to fund the GST component of a commercial property purchase
• Do not have capacity to repay the loan if the ATO GST refund is delayed, reduced, or disallowed
• Are acquiring property for personal, domestic, or household purposes (rather than business/commercial purposes)
• Have previously had GST input tax credit claims disallowed by the ATO in relation to property acquisitions

Explanation of why the product is likely to be consistent with the likely objectives, financial situation and needs of consumer in the target market

The product allows purchasers of commercial property who are registered for GST and entitled to claim an input tax credit to fund the GST component payable at settlement, bridging the short-term cash flow gap between settlement (when GST must be paid) and receipt of the ATO GST refund following lodgment of a Business Activity Statement (BAS).

The product addresses a specific and identifiable need: commercial property transactions in Australia attract GST at 10% of the purchase price, which is payable at settlement. Most commercial lenders do not fund this component, creating a short-term funding gap for purchasers even though the GST is recoverable. The product provides a targeted solution for this gap.

Consumer needs and objectives must relate to funding the GST on a commercial property purchase where the borrower is entitled to recover the GST through the BAS process. Customers must otherwise meet our eligibility criteria, including being registered for GST and entitled to claim the relevant input tax credit.

Distribution Conditions

This product can be distributed through the distributors set out below. All distribution channels require an application for the loan to be submitted to Property Credit via its website or the Property Credit sales team.

1. Direct – Property Credit’s website and sales team

Property Credit staff are adequately trained to assist applicants with loans and must follow all documented procedures to ensure that the product is distributed in accordance with this TMD. Property Credit will ask screening questions as part of the application to ensure that a prospective borrower is within the target market set out above, including verification of GST registration, entitlement to input tax credits, and the commercial nature of the property acquisition.

Property Credit considers this is an appropriate distribution channel because the nature of the target market and the requirement of all sales staff to have the necessary training, skills and knowledge to assess whether the consumer is within the target market and whether the product is in the best interest of the particular consumer.

Note: Property Credit may from time to time receive referrals from commercial property conveyancers, accountants, tax advisors, or commercial real estate agents. Where such persons act solely as “mere referrers” (limited to informing consumers that Property Credit can provide this product and providing Property Credit’s contact details), they are not treated as distributors for the purposes of this TMD and are not subject to the distribution conditions set out above. All lending decisions and target market assessments are made by Property Credit through its direct application process.

Review Triggers

The following events are review triggers that would reasonably suggest that the TMD is no longer appropriate:

• A significant dealing of the product to consumers outside the target market occurs.
• A significant number of systemic complaints are received from consumers in relation to the product.
• There is a material change by Property Credit to the product or the terms and conditions.
• There are significant and adverse changes in the credit performance of the product such as overdue payments, defaults or hardship applications.
• There are significant changes to Australian credit laws or tax laws that affect the product.
• Property Credit receives correspondence from a regulator, including an order or direction that directly states or implies that the TMD is no longer appropriate.
• A material change in ATO processing times for BAS refunds that may affect borrowers’ ability to repay within the loan term.
• A change in ATO policy regarding input tax credit eligibility for commercial property acquisitions.
• Legislative changes to the A New Tax System (Goods and Services Tax) Act 1999 (Cth) affecting the entitlement to input tax credits on commercial property acquisitions.
• A significant number of loans where the ATO GST refund received is materially less than the loan amount (indicating potential issues with eligibility assessment or target market definition).

Review Period

First review date
6 months after the date of this TMD

Period review
Every 12 months after the initial and each subsequent review.

Trigger Review
Review to be completed within 10 business days of the identification of a trigger event.

Reporting Requirements

As Property Credit is the sole distributor of this product (distributing directly via its website and sales team), the reporting requirements below are maintained as internal data collection and monitoring obligations. Property Credit will collect and record the following information from its own origination and sales processes to enable ongoing monitoring of the TMD’s appropriateness and to comply with its record-keeping obligations.