The AAT has upheld the Commissioner’s decision to reduce a taxpayer’s claim for the research and development (R&D) tax offset because the latter could not prove that the disputed expenditure was incurred. Facts The taxpayer was incorporated in 2006. It registered its R&D project for the 2006/07 income tax year with AusIndustry. The R&D activities involved manufacturing a children’s multi-layered “stacker” toy using an experimental and novel injection moulding process. The taxpayer claimed expenditure that included fees for personal services […]
In the matter of BAE Systems Australia Pty Ltd v Commissioner of Taxation, the Federal Court of Australia (FCA) reviewed whether the applicant, BAE Systems, is entitled to deductions under s 73B of the Income Tax Assessment (ITA) Act 1936. Background: The applicant taxpayer appeals from the Commissioner’s disallowance of objections made by the applicant in respect of amended income tax assessments issued by the Commissioner for the years of income ending on 31 March of 1993, 1994 and 1996. […]
Regarding the matter of Bartercard Australia and Commissioner of Taxation, the Administrative Appeals Tribunal (AAT) assessed what classified as income for Bartercard under the Income Tax Assessment (ITA) Act 1997 and whether expenditure by Bartercard on R&D was deductible under the special rules in s. 73B of the ITA Act 1936. Background: Bartercard received payments from terminating members in the total sum of $711,053.31 for the year ended 30 June 2002 and total $623,532.06 for the year ended 30 June […]
This matter concerns an application made by Zoffanies to the Administrative Appeals Tribunal (AAT) for the review of a decision of the Commissioner of Taxation to disallow Zoffanies objection against an Income Tax Assessment for the Substituted Accounting Period ending on 30 September 1992 (in lieu of the year ending on 30 June 1992). Background: Zoffanies, a subsidiary company of Macquarie Bank Ltd, claimed it was entitled to an allowable deduction of $109,947 which was part of a loss of […]