PREAMBLE
This Office has recently considered whether kelp harvesting comes within the definition of primary production in section 6 of the Income Tax Assessment Act.
FACTS
2. As presently understood kelp harvesting operations are limited to the gathering of storm cast kelp, from the sea or after it has been washed up on the shore, by mechanical or manual means. The kelp is then transported to a factory for processing. The operations at present do not involve in any way the cultivation of kelp.
RULING
3. Kelp harvesting is not considered to be primary production for the purposes of the Income Tax Assessment.
COMMISSIONER OF TAXATION
22 DECEMBER 1982