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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 […]

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. […]

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 […]

ATO ID 2006/68 Income Tax Research and Development: application of section 73CA of the ITAA 1936 to a reimbursement arrangement – expenditure ‘not at risk’

August 20th, 2014

Does section 73CA of the Income Tax Assessment Act 1936 (ITAA 1936) apply where an eligible company is entitled to reimbursement for expenditure on research and development activities in the form of a fee paid by a related entity? Yes. Section 73CA of the ITAA 1936 applies in this case to amounts calculated by reference to the eligible company’s own expenditure on research and development activities, as it is possible to conclude, for the purposes of the section, that the company is […]

Daniel McGregor

11. August, 2022

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.

John

15. June, 2022

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.

Rueben Rajasingam

6. June, 2022

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.

Enrique Esquivel

6. June, 2022

Damian and the team at Swanson Reed have been extremely helpfully and professional during all of our consultations. Highly recommended.

Jess at Y&C

3. June, 2022

Anatole Kononewsky

2. June, 2022

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.

Payam Toloo

2. June, 2022

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.

Melissa Doddy

31. May, 2022

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.

Gary Watson

31. May, 2022

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.

Rob van den Bergh

31. May, 2022

Always professional.

Daniel McGregor

11. August, 2022

John

15. June, 2022

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.

Rueben Rajasingam

6. June, 2022

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.

Enrique Esquivel

6. June, 2022

Damian and the team at Swanson Reed have been extremely helpfully and professional during all of our consultations. Highly recommended.

Jess at Y&C

3. June, 2022

Anatole Kononewsky

2. June, 2022

Payam Toloo

2. June, 2022

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.

Melissa Doddy

31. May, 2022

Gary Watson

31. May, 2022

Rob van den Bergh

31. May, 2022

Always professional.

What Our Clients Say

         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.
  
 
 
  
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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 […]

Swanson Reed News

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

ATO ID 2006/122 Income Tax Assessable income: derivation of Commonwealth funding – Cooperative Research Centres (CRC) Programme

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

ATO ID 2006/68 Income Tax Research and Development: application of section 73CA of the ITAA 1936 to a reimbursement arrangement – expenditure ‘not at risk’

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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

ATO ID 2006/122 Income Tax Assessable income: derivation of Commonwealth funding – Cooperative Research Centres (CRC) Programme

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

ATO ID 2006/68 Income Tax Research and Development: application of section 73CA of the ITAA 1936 to a reimbursement arrangement – expenditure ‘not at risk’

Are You Eligible?

R&D Audit Checklist

Categories

Archives

What Our Clients Say

Quick Contact

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