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Tax Group recommends scrapping R&D benefits to fund company tax cut

The Business Tax Working Group has recommended scrapping the R& benefit for companies with turnover of more than $20 million, capping interest deductions and removing some deductions for exploration and prospecting in order to fund a company tax cut. The release of the BTWG’s discussion paper comes after reports emerged last week it would recommend […]
Patrick Stafford
Patrick Stafford

The Business Tax Working Group has recommended scrapping the R& benefit for companies with turnover of more than $20 million, capping interest deductions and removing some deductions for exploration and prospecting in order to fund a company tax cut.

The release of the BTWG’s discussion paper comes after reports emerged last week it would recommend scrapping R& benefits to pay for the cut โ€“ a move several employer groups spoke out against.

The new report recommends that in order to pay for the cut, the Federal Government should abolish the 40% non-refundable tax offset, which is available for businesses earning more than $20 million.

โ€œCompanies would instead be entitled to deductions for R& expenditure under the normal deduction provisions in the tax law,โ€ it says.

But it also gives other options, including imposing a turnover threshold above which the 40% cannot be claimed, which would affect a โ€œsmall number of very large companies with very large R& spendsโ€.

It also suggests imposing a cap on smaller SMEs for their own R& spending, or reducing the non-refundable tax offset to just 37.5%.

โ€œReducing the rate of the non-refundable tax offset recognises that companies with an aggregated annual turnover greater than $20 million generally have greater capacity to undertake R& and therefore may require less assistance than is currently provided.โ€

If the government cuts the corporate tax rate to 25% would cost $26 billion, although cutting it to 28% โ€“ as originally promised by the government โ€“ would cost just $10.4 million over the next four years.

Cutting to 29% would cost $5.4 billion.

โ€œIt is inevitable that a company tax rate cut funded through measures that broaden the corporate tax base will generally involve a redistribution from those who benefit from existing concessions to the broader corporate taxpaying base, at least in the short term,โ€ it says.

The recommendations are broken into three key parts: interest deductibility, capital allowances and treatment of expenditures, and the R& tax incentive.

Interest deductibility

The recommendations include removing armโ€™s length tests and reducing safe harbour gearing levels for general entities, which would reduce the safe harbour maximum debt limit for general entities from 75% to 60%.

It also recommends reducing safe harbours for financial institutions, capping interest deductions for all business taxpayers, with or without including banks โ€“ it recommends either way could work.

Depreciating assets and capital expenditure

As for deductions, the report recommends reducing the diminishing value rate for depreciation from 200% to 150%, and removing the capped effective life provided to certain depreciating assets.

As for exploration, the report suggests removing or reducing the โ€œfirst useโ€ exploration deduction, and the removal of immediate deductions for exploration conducted by large companies.

One option recommended would see building depreciation deductions, or allow a uniform rate of depreciation of 2.5% per annum.

R& tax incentive

There are four key proposals for the R& concession: Abolish the 40% non-refundable tax offset; impose a turnover threshold for the 40% offset; impose a cap for all other SMEs; and cut the rate to 37.5%.

Businesses have been invited to submit responses to the discussion paper, with a final report due in October.