Tax Changes - Australian Non-Commercial Loss Provisions

In last week's Federal Budget, the Australian
government announced an extension of the1. Does the business have assessable income of
anti-avoidance provisions that deal withat least $20,000 in an income year?
non-commercial business losses.2. Has the business produced a profit in three out
First, some background.of the past five years?
For some years, the government and the Tax3. Does the business use real property or an
Office have been concerned about peopleinterest in real property worth at least $500,000
obtaining tax deductions for what are, in effect,on a continuing basis?
hobbies. For example, a person has a small4. Does the business use other assets worth at
vineyard from which they make small quantitiesleast $100,000 on a continuing basis?
of wine. There are some sales of the wine, but itPassing these tests, particularly for wealthy
is nowhere near enough to cover the costs ofpeople, is not that difficult. So, the government
production. So, the "business" makes a loss andhas reacted to make it even more difficult for
the person claims this as a tax deduction. Often,people on high incomes to be able to claim a tax
the person claiming the tax deduction has a highdeduction for losses from their business activities.
salary income. Hence the expression "Pitt StreetThe change is that people with "adjusted taxable
farmer" (for New South Wales) and "Collins Streetincome" of over $250,000 will have excess
farmer" (for Victoria). (Those living in other statesdeductions quarantined to the business activity.
will have to make up their own phrase).This appears to be a "blanket" exception to the
So, for a number of years now, we have had infour tests I mention above. For people with an
the Australian taxation law what are known asadjusted taxable income of $250,000 or less, the
the non-commercial loss provisions. If theseexisting rules will continue to apply.
provisions apply, they prevent the claiming of aThe Treasurer has referred to the ability of
tax loss immediately from what the legislationwealthy people to claim tax deductions in the
defines as a non-commercial activity. However,circumstances outlined above as a "loophole".
the tax loss can be carried forward to be set offAccordingly, the government will move quickly to
against future income from the business activity.close this tax planning opportunity from 1 July
In certain circumstances, even though a loss has2009. It should be remembered, that this is only
been made, the losses can still be claimed as aan announcement and the legislation must be
tax deduction. The idea of these exceptions waspassed by Parliament before it is effective. The
to try and ensure that people who are carryingexact application of the changes to the
on genuine businesses are not get caught bynon-commercial loss provisions may be somewhat
these provisions. Broadly, you can offset lossesdifferent after it has passed through the
from the business activity against other income ifparliamentary process.
the business activity passes at least one of theWishing you easier business...
following four tests: