Swanson Reed News

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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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 […]

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ATO ID 2005/358 Income tax Research and Development: ‘Aggregate research and development amount’ where core technology expenditure not deducted

August 19th, 2014

Where an eligible company chooses not to deduct an amount of core technology expenditure under subsection 73B (12A) of the Income Tax Assessment Act 1936 (ITAA 1936), is the amount included in the company’s ‘aggregate research and development amount’ as defined in subsection 73B(1) of the ITAA 1936? Yes. The amount allowable as a deduction under subsections 73B(12) or (12A) of the ITAA 1936 for core technology expenditure is included in the ‘aggregate research and development amount’ of an eligible company. The […]

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Bryce Steele
Principal, Melbourne
Tel: (03) 9018 5778
Mob: 0401 997 584
Tom Parkhouse
Principal, Sydney
Tel: (02) 8006 0559
Mob: 0411 718 565
Andy Nguyen
Principal, Brisbane
Tel: (07) 3221 1499
Mob: 0407 750 249
Sophie Mercer
Principal, Adelaide
Tel: (08) 8121 7850
Mob: 0435 713 493
David Greatwich
Principal, Perth
Tel: (08) 9340 3745
Mob: 0468 386 250
Myriam Risch
Manager, Hobart
Tel: (03) 9018 5778
Mob: 0401 262 591

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