ATO Guidance and Materials

ATO ID 2002/985 Income Tax Research and Development – 3 Year History – Additional Deduction

August 19th, 2014

Does the taxpayer satisfy the requirement of establishing a three year history outlined in paragraph 73Q(1)(b) of the Income Tax Assessment Act 1936 (ITAA 1936), for the three years preceding the 2002 financial year? Yes. The taxpayer was in receipt of an Research & Development (R&D) Start Grant for the 1999 and 2000 financial years and was registered with the Industry Research and Development Board (IRDB), under section 39J of the Industry Research and Development Act 1986 (IR&DA) for the 2001 financial year. The […]

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TD 2014/15 Income tax: when is Design Expenditure incurred by an R&D entity included in the first element of the cost of a tangible depreciating asset for the purposes of paragraph 355-225(1)(b) of the Income Tax Assessment Act 1997 (and therefore not able to be deducted under section 355-205)?

August 19th, 2014

This Taxation Determination is concerned with where an R&D entity 1 incurs expenditure on various stages of design activities ( Design Expenditure ), connected with it beginning to hold a tangible depreciating asset, where that expenditure also falls within the terms of section 355- 205.2 This expenditure will typically be incurred in cases where the R&D entity is constructing the asset itself, or having another entity construct it on its behalf, as distinct from acquiring the asset ‘off the shelf’. […]

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TR 2013/3 Income tax: research and development tax offsets: feedstock adjustments

August 19th, 2014

Summary of 104 160 689 matter Taxation Ruling: TR 2013/3A1 – Addendum Click Here  GHP 104 160 689 Pty Ltd v. Commissioner of Taxation Click Here Decision Impact Statement – GHP 104 160 689 Pty Ltd Click Here *This must be read in conjunction with Taxation Ruling: TR 2013/3A1 – Addendum Paragraph 355-465(1)(a) sets out the first condition for a feedstock adjustment to arise. This paragraph refers to three tests that must be satisfied for the first condition to be […]

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ATO ID 2014/11 Income Tax Research and Development: building expenditure

August 19th, 2014

Does the exclusion for ‘expenditure incurred in the acquisition or construction of a building’ in the definition of ‘research and development expenditure’ in subsection 73B(1) of the Income Tax Assessment Act 1936 (ITAA 1936) only include structural elements that form the building? No. ‘Building’ for the purposes of subsection 73B(1) of the ITAA 1936 also includes ‘a part of’ a building. For this purpose, ‘a part of’ a building takes on its ordinary meaning and refers to structural components of a building […]

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