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ATO ID 2006/138 Income Tax Research and development: consolidated group – R & D activities of two subsidiary members – only one registered

August 20th, 2014

Can the head company of a consolidated group claim deductions under section 73B of the Income Tax Assessment Act 1936 (ITAA 1936) for research and development expenditure incurred by a subsidiary member where the only member of the consolidated group registered in relation to the relevant research and development activities is another subsidiary member? Yes. The head company can claim a deduction under section 73B of the ITAA 1936 in respect of the research and development expenditure of the subsidiary member. In […]

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ATO ID 2006/137 Income Tax R&D: consolidated group – R & D activities of subsidiary member deemed to be carried out on behalf of head company

August 20th, 2014

Does subsection 73B(9) of the Income Tax Assessment Act 1936 (ITAA 1936), when affected by the single entity rule (section 701-1 of the Income Tax Assessment Act 1997 (ITAA 1997), prevent the head company of a consolidated group from claiming a deduction under section 73B of the ITAA 1936, for expenditure on research and development activities carried out on behalf of a subsidiary member of the consolidated group? No Research and development activities carried out ‘on behalf of’ a subsidiary member of […]

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ATO ID 2006/136 Income Tax Research and development: consolidated group – effect of single entity rule – R & D activities of subsidiary deemed to be carried out on behalf of head company

August 20th, 2014

Is the effect of the single entity rule (section 701-1 of the Income Tax Assessment Act 1997 (ITAA 1997)) such that the head company of a consolidated group is considered to have carried out on its own behalf the research and development activities carried out by or on behalf of its subsidiary member for the purposes of the definition of research and development expenditure, in subsection 73B(1) of the Income Tax Assessment Act 1936 (ITAA 1936)? Yes. Research and development activities carried out by […]

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ATO ID 2006/122 Income Tax Assessable income: derivation of Commonwealth funding – Cooperative Research Centres (CRC) Programme

August 20th, 2014

Are instalments paid to a taxpayer (CRC Company) under the Commonwealth Agreements for the 2004 and 2006 Selection Rounds of the CRC Programme (the Agreements), derived at the time of receipt for the purposes of section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997)? No. Instalments paid to a CRC Company under the Agreements are not derived for the purposes of section 6-5 of the ITAA 1997 until applied toward the conduct of the ‘Activities’, as specified in the Agreements. […]

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Alex Chisholm
Principal, Melbourne
Tom Parkhouse
Principal, Sydney
Andy Nguyen
Principal, Brisbane
Holly Parkinson
Manager, Adelaide
David Greatwich
Principal, Perth
Krishna Gungaram
Manager, Hobart

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