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ATO Guidance and Materials

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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ATO ID 2006/74 Income Tax Research and Development: subsection 73B(3B) – partnership

August 20th, 2014

Is there a ‘partnership’ under subsection 73B(3B) of the Income Tax Assessment Act 1936 (ITAA 1936), where two companies collaborate to conduct research and development activities, and to engage the services of a third to conduct some of these activities on their behalf? Yes. The collaboration between the two companies results in a ‘partnership’ under subsection 73B(3B) of the ITAA 1936, as the joint conduct of the research and development activities is ‘taken to constitute carrying on business with a view to […]

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