Home » News » August 2014

August, 2014

ATO ID 2006/238 Income tax Research and development: unpaid wages

August 20th, 2014

Can an eligible company claim a deduction for certain ‘unpaid wages’ under subsection 73B(14) of the Income Tax Assessment Act 1936 (ITAA 1936)? No. The company cannot claim a deduction under subsection 73B(14) of the ITAA 1936 in respect of the ‘unpaid wages’ that have not been incurred by the company. The company is an ‘eligible company’ which undertakes on its own behalf ‘research and development activities’, as defined by subsection 73B(1) of the ITAA 1936. The company’s ‘research and development activities’ […]

Read More

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 […]

Read More

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 […]

Read More

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 […]

Read More

Categories

Archives