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TR 2013/3 Income tax: research and development tax offsets: feedstock adjustments

August 19th, 2014

Summary of 104 160 689 matter

Taxation Ruling: TR 2013/3A1 – Addendum	Click Here
GHP 104 160 689 Pty Ltd v. Commissioner of Taxation	Click Here
Decision Impact Statement – GHP 104 160 689 Pty Ltd	Click Here

*This must be read in conjunction with Taxation Ruling: TR 2013/3A1 – Addendum

Paragraph 355-465(1)(a) sets out the first condition for a feedstock adjustment to arise. This paragraph refers to three tests that must be satisfied for the first condition to be met as outlined below:

· an R&D entity incurs expenditure in one or more income years in acquiring or producing goods, or materials (the feedstock inputs);

· the feedstock inputs are transformed or processed;

·feedstock inputs are transformed or processed during R&D activities in producing one or more tangible products (feedstock outputs).

The words ‘expenditure … in acquiring or producing goods, or materials’ form a composite phrase in paragraph 355-465(1)(a), where that phrase describes expenditure of a particular character ¹¹ and is limited in its scope to only covering expenditure incurred up to the time transformation or processing activities begin. This expenditure does not include expenditure incurred on the transformation or processing of the relevant goods or materials, with the exception of certain expenditure found in multistage production processes (discussed in paragraphs 24 and 26 of this Ruling).

This character concerns expenditure incurred in acquiring or producing goods or materials which have been ‘transformed or processed during R&D activities in producing one or more tangible products (the feedstock outputs) ‘, as indicated by the concluding words of the first condition. The fact that the expenditure must be of this character and have resulted in tangible products being produced is an important part of the first condition. If this precondition is not met then a feedstock adjustment will not happen.

Click here for full Tax Ruling.

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   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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TR 2013/3 Income tax: research and development tax offsets: feedstock adjustments

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