Tax Determinations

Taxation Ruling: TR 2013/3A1 – Addendum

September 7th, 2015

Summary of 104 106 689 matter Taxation Ruling – TR2013/3 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 the original Taxation Ruling – TR2013/3 Following the AAT decision in GHP 104 160 689 Pty Ltd v. Commissioner of Taxation, an amendment has been made to the Taxation ruling TR 2013/3 to remove the discussion on […]

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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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TD 2014/15 – Treatment of Design Expenditure relating to an Asset

July 14th, 2014

The ATO recently issued TD 2014/15.  This Tax Determination relates to the R&D tax incentive and discusses the treatment of expenditure incurred by an R&D entity during various design stages (Design Expenditure) connected with it beginning to hold a tangible depreciating asset, where that expenditure also falls within the terms of section 355-205 of the Income Tax Assessment Act 1997 (ITAA97). The determination addresses the question of when to include the Design Expenditure in the first element of the cost […]

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