Swanson Reed News

ATO ID 2009/107 Income Tax R&D tax concession

August 20th, 2014

Under section 73CA of the Income Tax Assessment Act 1936 (ITAA 1936), is a company ‘not at risk’ in respect of an amount of expenditure if: The company incurs the expenditure in an effort to comply with a contractual obligation to deliver a certain product; and when it is incurred, it can reasonably be expected that, as a result, the company will earn a fee under the contract at least equal to the amount of the expenditure; and that expectation is held […]

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ATO ID 2008/130 Income Tax Income tax treatment of securitisation of leases

August 20th, 2014

Does an entity that acquires motor vehicles, leases them and assigns all of its rights under the leases including an amount specified as the residual value of the motor vehicles, to a special purpose vehicle under a securitisation arrangement, hold the motor vehicles as trading stock for the purposes of Division 70 of the Income Tax Assessment Act 1997 (ITAA 1997)? No. The entity does not, in the circumstances described above, hold the motor vehicles as trading stock for the purposes of […]

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ATO ID 2008/115 Income Tax Eligibility for Tax Offset: R&D tax offset and exempt entity ownership exception

August 20th, 2014

Does the exception in subsection 73J(2) of the Income Tax Assessment Act 1936 (ITAA 1936) apply, to prevent an eligible company choosing the tax offset under section 73I of the ITAA 1936, where the less than 25% exempt entity ownership requirement may not be breached if actual and potential future interests are taken into account? Yes. The exception in subsection 73J(2) of the ITAA 1936 applies if the interests actually owned, by an entity or entities referred to in the subsection, carry […]

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ATO ID 2006/328 Income Tax Capital Allowances: cost – ‘section 73BA depreciating asset’ – new full-scale test model – re-use of components from earlier test model

August 20th, 2014

Yes. The first element of cost of the new test model does include, pursuant to subsection 40-180(3) of the ITAA 1997, the cost attributed to those components of the earlier test model that have been re-used in building the new test model. The taxpayer is an ‘eligible company’, as defined in subsection 73B(1) of the Income Tax Assessment Act 1936 (ITAA 1936), that carries on ‘research and development activities’ (R&D activities) as defined in subsection 73B(1). The taxpayer has registered its R&D […]

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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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