Consultation
Research and Development (R&D) Tax Incentive: Targeting Access
Name
Mr Frederick John Morgan
Submission text
To Treasury 

Research and Development (R&D) Tax Incentive: Targeting Access 

1. I note that the proposed s355-103 proposes using a $20b turnover threshold based on aggregating the assessable income of the R&D Entity with that of the entities that are its 'affiliates' and also those which are 'connected with' it, under Div 328 of the ITAA97. 

2. I note that these definitions have caused considerable difficulty in the 'small business CGT concession' context. 

3. I realise that the affected businesses will be very large (with $20b turnovers) and therefore have much greater resources to try and work out whether there are entities whose assessable income must be included. 

4 Even so, I think they are definitions that are very difficult, and you might look again at how appropriate they are. 

Thank you, 
John Morgan 
Barrister at Law. 
12.5.13