Swanson Reed News

GHP 104 160 689 Pty Ltd v. Commissioner of Taxation

March 7th, 2015

Summary of 104 160 689 matter Taxation Ruling – TR2013/3 Click Here  Taxation Ruling: TR 2013/3A1 – Addendum Click Here Decision Impact Statement – GHP 104 160 689 Pty Ltd  Click Here The case concerned whether certain expenditure was to be disallowed deductibility at the rate of 125% because it was ‘feedstock expenditure’ within the meaning of the former section 73B(1) of ITAA 1936. GHP 104 160 689 Pty Ltd (‘the applicant’) carried on the business of mining operations which […]

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Good News Flash – Proposed reduction to R&D offset rate rejected by Senate

March 4th, 2015

At the announcement of the May 2014 budget, the Federal Government proposed to decrease the refundable and non-refundable R&D tax offsets by 1.5% for FY15. The reduction in the R&D tax offset rates was proposed to commence one year prior to the 1.5% reduction in corporate rate for FY16. Had the R&D Tax Offset rates reduced one year prior to the corporate tax rate as proposed, the permanent effective benefit of the R&D Tax Incentive would have dropped in FY15, then been […]

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ATO ID 2015/5 Research and Development: Disposal of research & development results and future payments

February 17th, 2015

Does the disposal of research and development (R&D) results provision in section 355-410 of the Income Tax Assessment Act 1997 (ITAA 1997) include amounts from the licensing of intellectual property (IP) payable in the future, subject to achieving future development and sales milestones? Yes. The disposal of R&D results provision in section 355-410 of the ITAA 1997 includes amounts from the licensing of IP payable in the future. These include future payments that are referrable to future development of the IP and […]

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ATO ID 2015/4 Income tax: Research and Development: Disposal of research and development results

February 17th, 2015

Does the R&D disposal of results provision in section 355-410 of the Income Tax Assessment Act 1997 (ITAA 1997) contemplate apportioning an amount received by an R&D entity where the amount comprises of payment for results from research and development (R&D) and non-R&D activities? Yes. Section 355-410 of the ITAA 1997 is only concerned with bringing to account the disposal proceeds for the results for which an R&D entity is entitled to a tax offset under Division 355 of the ITAA 1997 […]

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

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