Become a Member
Membership
Education
Events
Resources
Tax Knowledge Exchange
About us
Contact us
  Miscellaneous 2009

Public private partnerships: Capital allowance deductions for infrastructure projects

Source: Australian Tax Forum Journal Article

Published Date: 1 Nov 2009

 
Capital allowance deductions for the assets used in PPP infrastructure projects can be denied to the private sector participant in the project where government retains the economic ownership of the asset. Two sets of rules that attempted to characterise PPP arrangements where government retained economic ownership had led to taxpayer uncertainty and delays in projects. The Ralph Review of Business taxation recommended that these rules be replaced with ones that would create more certainty for private sector participants in PPP projects. The rules that have now been inserted, after an aborted attempt at using banking type concepts of risk allocation as a measure of economic ownership, use concepts of control of use and predominant economic ownership to identify transactions where capital allowance deductions are denied. That, together with more generous safe harbours, specific exclusions and better clarification of control, seems to have achieved the desirable outcome of private sector participants being able to consider the application of these rules to a project with reasonable certainty.
Author(s)

Sorry, this is subscriber only content.

To gain access to this material and much more - Subscribe Now.

(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).

Already a Subscriber? Login now

Subscribe Now

Already a Subscriber? Login now

Download

Details

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.

Tags

Miscellaneous 2009

Share this page