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ATO ID 2006/259 Income Tax Capital Allowances: depreciating asset – section 73BA depreciating asset – full-scale test model
August 20th, 2014Is the full-scale test model of an item of equipment, which is the subject matter of the taxpayer’s research and development (R&D) activities, a ‘section 73BA depreciating asset’ within the meaning of that term in section 73BB of the Income Tax Assessment Act 1936 (ITAA 1936) for which the taxpayer has a ‘notional Division 40 deduction’ within the meaning of section 73BC of the ITAA 1936? Yes. The full-scale test model is a ‘section 73BA depreciating asset’ because the test […]
ATO ID 2006/238 Income tax Research and development: unpaid wages
August 20th, 2014Can 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’ […]
ATO ID 2006/138 Income Tax Research and development: consolidated group – R & D activities of two subsidiary members – only one registered
August 20th, 2014Can 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 […]
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, 2014Does 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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News & Research
News & Research
News & ResearchIndependent Review of TPB Makes Reference to R&D Tax Practitioners
Regulation of the tax profession is the responsibility of the Tax Practitioners Board (TPB) which was formed following the Tax Agent Services Act 2009 (TASA)’s introduction. An independent review into the effectiveness of the TPB has been undertaken over recent […]
Commentary in Tax Institute’s TaxVine Journal calls for Stability to R&D Tax Incentive
This week’s TaxVine Journal (the weekly publication of The Tax Institute) featured some commentary from Mariana von Lucken of HLB Mann Hudd, supportive of the Government’s budget announcements and echoing Swanson Reed’s previous calls for stability to the R&D Tax […]
