Home » News » ATO ID 2012/89 – R&D Feedstock adjustments – creation of a prototype

ATO ID 2012/89 – R&D Feedstock adjustments – creation of a prototype

August 15th, 2014

Does a ‘feedstock adjustment’ arise under section 355-465 of the Income Tax Assessment Act 1997 (ITAA 1997) in relation to expenditure incurred by an ‘Research and Development (R&D) entity’ in creating a prototype which is a depreciating asset, but not one used in acquiring or producing any ‘feedstock inputs’?

Simply, the answer is no. A feedstock adjustment does not arise under section 355-465 of the ITAA 1997 where an R&D entity incurs expenditure on constructing a prototype which is a tangible depreciating asset, where that asset is not used in acquiring or producing any ‘feedstock inputs’.

Feedstock adjustments depend, among other conditions, on the R&D entity obtaining a tax offset under section 355-100 of the ITAA 1997 for an income year, but only for certain kinds of notional deductions covered by Division 355 of the ITAA 1997. A notional deduction for the decline in value of a depreciating asset which is not used in acquiring or producing any feedstock inputs is not one of these kinds, and so section 355-465 of the ITAA 1997 does not apply.

This is because Division 355 allows certain taxpayers (being an R&D entity within the meaning of section 355-35) a tax offset based on prescribed percentages of the total of the notional deductions they are entitled to under seven specific sections in the Division, including section 355-205 (R&D expenditure) and section 355-305 (decline in value of R&D assets).

Subsection 355-205(1) allows an R&D entity to notionally deduct expenses incurred on R&D activities, where the conditions of that subsection are met. This is subject to section 355-225 (excluded expenditure): see subsection 355-205(2).

Click here for the full Interpretative Decision.

Are You Eligible?

Click here for the R&D Eligibility Wizard

R&D Audit Checklist

Archives

         Posted on Google  
   
   Daniel McGregor  
 11. August, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  I have been using Swanson Reed for my clients for more than a decade.  Having a specialist firm that can provide practical and commercial advice that produces real outcomes is very important and we have received great feedback from our clients. Highly recommended.
  
 
 
      Posted on Google  
   
   John  
 15. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Damian and the rest of the team at Swanson Reed have been supporting us for several years.  We always appreciate their insights, expertise, and efforts.
  
 
 
      Posted on Google  
   
   Rueben Rajasingam  
 6. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Experienced responsive Team. They have been a great help to me and my company navigate the R&D tax claim process and have provided invaluable advice.
  
 
 
      Posted on Google  
   
   Enrique Esquivel  
 6. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Damian and the team at Swanson Reed have been extremely helpfully and professional during all of our consultations. Highly recommended.
  
 
 
      Posted on Google  
   
   Jess at Y&C  
 3. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  
  
 
 
      Posted on Google  
   
   Anatole Kononewsky  
 2. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  The Swanson Reed team have provided our company with exceptional professional advice and assistance for all of our R&D claims for many years - have always achieved great results with excellent value for their services.
  
 
 
      Posted on Google  
   
   Payam Toloo  
 2. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Damian Smyth and his team are very helpful, supportive and experts in their field of R&D Tax claims. I'm always happy with the work they do and been a customer of their for over 5 years.
  
 
 
      Posted on Google  
   
   Melissa Doddy  
 31. May, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  The Team at Swanson Reed are very experienced R&D Tax Advisors and gave us ongoing support with all of our R&D Claims, the consultants ensured we were always working with current legislative guidelines, gave us assistance with compiling technical and government documentation and went out their way to ensure they were with us for the entire process from beginning to end.  Highly recommended to anyone who needs assistance with working through what can at times be a daunting process.
  
 
 
      Posted on Google  
   
   Gary Watson  
 31. May, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  We can highly recommend Swanson and Reed as an R & D accountant. We have worked with them for several years now as they make our R & D claim so easy and communicate quickly with both us and our accountant.
  
 
 
      Posted on Google  
   
   Rob van den Bergh  
 31. May, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Always professional.
  
 
 
  
  Load more

         Posted on Google  
   
   Daniel McGregor  
 11. August, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  I have been using Swanson Reed for my clients for more than a decade.  Having a specialist firm that can provide practical and commercial advice that produces real outcomes is very important and we have received great feedback from our clients. Highly recommended.
  
 
 
      Posted on Google  
   
   John  
 15. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Damian and the rest of the team at Swanson Reed have been supporting us for several years.  We always appreciate their insights, expertise, and efforts.
  
 
 
      Posted on Google  
   
   Rueben Rajasingam  
 6. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Experienced responsive Team. They have been a great help to me and my company navigate the R&D tax claim process and have provided invaluable advice.
  
 
 
      Posted on Google  
   
   Enrique Esquivel  
 6. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Damian and the team at Swanson Reed have been extremely helpfully and professional during all of our consultations. Highly recommended.
  
 
 
      Posted on Google  
   
   Jess at Y&C  
 3. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  
  
 
 
      Posted on Google  
   
   Anatole Kononewsky  
 2. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  The Swanson Reed team have provided our company with exceptional professional advice and assistance for all of our R&D claims for many years - have always achieved great results with excellent value for their services.
  
 
 
      Posted on Google  
   
   Payam Toloo  
 2. June, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Damian Smyth and his team are very helpful, supportive and experts in their field of R&D Tax claims. I'm always happy with the work they do and been a customer of their for over 5 years.
  
 
 
      Posted on Google  
   
   Melissa Doddy  
 31. May, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  The Team at Swanson Reed are very experienced R&D Tax Advisors and gave us ongoing support with all of our R&D Claims, the consultants ensured we were always working with current legislative guidelines, gave us assistance with compiling technical and government documentation and went out their way to ensure they were with us for the entire process from beginning to end.  Highly recommended to anyone who needs assistance with working through what can at times be a daunting process.
  
 
 
      Posted on Google  
   
   Gary Watson  
 31. May, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  We can highly recommend Swanson and Reed as an R & D accountant. We have worked with them for several years now as they make our R & D claim so easy and communicate quickly with both us and our accountant.
  
 
 
      Posted on Google  
   
   Rob van den Bergh  
 31. May, 2022
 
 
 Trustindex verifies that the original source of the review is Google.  Always professional.
  
 
 
  
  Load more

News & Research
News & Research

Draft legislation released for R&D Tax Measures announced in May 2026 Federal Budget

In the Federal Budget handed down on 12 May 2026, The Government proposed major structural changes to the R&D Tax Incentive (RDTI) proposed to commence on 1 July 2028. Proposed reforms announced in May 2026 include: Increasing the offset for […]

DISR Agrifood sector guide for the R&D Tax Incentive

DISR has recently published new specific guidance for the sector. The guidance, titled ‘Agrifood sector guide for the R&D Tax Incentive’ includes worked examples of R&D activity assessment and relevant records claimants should keep. Companies and stakeholders interacting with the […]

ATO ID 2012/89 – R&D Feedstock adjustments – creation of a prototype

Are You Eligible?

R&D Audit Checklist

Quick Contact

Categories

Archives

What Our Clients Say

Quick Contact

News & Research
News & Research

ATO ID 2012/89 – R&D Feedstock adjustments – creation of a prototype

Are You Eligible?

R&D Audit Checklist

Quick Contact

Categories

Archives

What Our Clients Say

Quick Contact

News & Research News & Research

News & Research
News & Research