The significant outcome of the Australian High Court decision in the MBI Properties case was that a supply can arise even when a taxpayer passively remains bound by the actions of another, such as agreeing to be bound by the terms of an existing property lease. After this decision, the mere passive holding of property can result in GST liability. In this article, the author reviews the arguments put forward by the parties in this case, along with the decision of the Court and the subsequent Decision Impact Statement issued by the Australian Tax Office related to the case.