In the case of Ozone Manufacturing Pty Ltd v Commissioner of Taxation, the Administrative Appeals Tribunal has affirmed the Commissioner’s decision to refuse a taxpayer’s claim for a tax offset under s 73I ITAA 1936 for the 2001-2002 tax offset year.
Background
Decision
The AAT found that the taxpayer did not:
Learning Points
Good record-keeping is not just good business practice, it’s a legal requirement. These decisions in the AAT have highlighted that activities and expenditure must be supported and substantiated by relevant source documentation.
In September 2013, the Australian Tax Office (ATO) emphasised this case in its Large Business Bulletin. The ATO highlighted the importance of contemporaneous documentation and urged companies to avoid costly R&D record-keeping mistakes.
Re Ozone Manufacturing Pty Ltd and FCT [2013] AATA 420 (Senior Member R W Dunne, 21 June 2013