I don't have a "ruling" (as I don't do the integrated course) but I do have an ATO "determination" in the filing cabinet which says much the same thing, that only CPL training is exempt from GST, ie "That training which is not undertaken by a PPL holder" I also asked one of my students, who is a tax officer specialising in GST...and basically it is all down to interpretation.
To co-erce a PPL wannabee into saying they want to do a CPL when they don't have that INTENTION so that you can undercut the competition who are charging GST on PPL training is to my eyes wrong, but that's just my interpretation of it. It's a cut throat world out there.
OF course, if a student feels they have been charged the GST when they shouldn't have been , there is nothing to stop them from claiming it back at tax time.
We all know that many are abusing the "integrated course" some people stretch it out for years and never attend any ground school, but that's one for CASA to sort out.
:rolleyes:

It is not just a matter of the GST. I advise every prospective pilot who thinks they might one day go on to CPL, to commence the 150 hour course according to Reg. 5.111. If you start a PPL and then decide to go on to CPL, 200 hours is required under Reg. 5.115. And the only difference is the timing of the exams. So why risk it.