Income tax: effective life of depreciating assets (applicable from 1 July 2018)
Please note that the PDF version is the authorised version of this ruling.This document has been Withdrawn.View the Withdrawal notice for this document.
This publication provides you with the following level of protection:
This publication (excluding appendixes) is a public ruling for the purposes of the Taxation Administration Act 1953.
A public ruling is an expression of the Commissioner's opinion about the way in which a relevant provision applies, or would apply, to entities generally or to a class of entities in relation to a particular scheme or a class of schemes.
If you rely on this ruling, the Commissioner must apply the law to you in the way set out in the ruling (unless the Commissioner is satisfied that the ruling is incorrect and disadvantages you, in which case the law may be applied to you in a way that is more favourable for you - provided the Commissioner is not prevented from doing so by a time limit imposed by the law). You will be protected from having to pay any underpaid tax, penalty or interest in respect of the matters covered by this ruling if it turns out that it does not correctly state how the relevant provision applies to you.
Summary - what this Ruling is about
1. This Ruling explains the methodology used by the Commissioner of Taxation to make a determination of the effective life of depreciating assets under section 40-100 of the Income Tax Assessment Act 1997 (ITAA 1997). 
2. The effective life of a depreciating asset is used to work out the asset's decline in value (depreciation for income tax purposes).  The Commissioner makes the effective life determination having regard to the period the depreciating asset can be used for a purpose specified in subsection 40-100(5) (a specified purpose  ), one of which is use for a taxable purpose. A deduction may be available under Division 40 for the depreciating asset's decline in value, to the extent that the asset is used for a taxable purpose (see section 40-25).
4. You may choose to use the Commissioner's determination of the effective life of a depreciating asset or you may make your own estimate (see section 40-95). This Ruling's explanation of the methodology used by the Commissioner to make a determination of effective life may assist taxpayers who make their own estimate of the effective life of a depreciating asset.
5. This Ruling replaces Taxation Ruling TR 2017/2 Income tax: effective life of depreciating assets (applicable from 1 July 2017) , which is withdrawn from 1 July 2018. Where the Commissioner's views in that Ruling still apply, they are incorporated into this Ruling.
Effective life determination
6. The Commissioner has made a determination of the effective life of certain depreciating assets which takes effect from 1 July 2018. This determination has been incorporated into Tables A and B of this Ruling.
Effective life applicable
- you entered into the contract to acquire it
- you started to construct it, or
- you otherwise acquired it
the effective life that applies is the one in force at the relevant time (see section 40-95).
9. If you do not start to use a depreciating asset or have it installed ready for use within the five year period, the effective life that applies is the one in force at the date you first use the depreciating asset or have it installed ready for use for any purpose (see section 40-95).
How to use Tables A and B
10. Table A is an industry category table. It lists assets that are specific to a particular industry or for which a particular effective life is appropriate because of the way the asset is used in that industry. Industry headings in Table A are generally drawn from the classification subject categories in the Australian and New Zealand Standard Industrial Classification (ANZSIC) codes.
- Only a participant of a listed industry can use the Table A entries for that industry.
- If an asset either corresponds exactly to a description in Table A for the industry in which it is used or it satisfies the general description of an asset used in the functional process of that industry, the effective life is the life specified.
- If the particular asset is not listed under your industry heading in Table A, either specifically or under a general functional group or class, the industry participant can use a relevant effective life shown in Table B.
- Taxpayers in an industry can only use Table B entries if the particular asset is not listed under the relevant industry heading in Table A.
- If the taxpayer is not using the asset in an industry specified in Table A and the asset corresponds to a description in Table B, the effective life is the life specified for that description.
12. Taxpayers must be satisfied that an asset is a depreciating asset  before using an effective life determination in Table A or B. An asset that is a depreciating asset for a particular taxpayer or industry may not necessarily be a depreciating asset for another taxpayer or industry.
13. If a particular asset is not listed in either Table A or B, it means the Commissioner has not made a determination of its effective life. You will need to work out its effective life yourself (see section 40-105 and paragraphs 46 to 49 of this Ruling).
To find an asset for a particular asset category, go to Effective lives (Industry category)
To find an asset using an alphabetical listing, go to Effective lives (By asset)
Date of effect
14. This Ruling applies from 1 July 2018. However, the Ruling does not apply to taxpayers to the extent that it conflicts with the terms of a settlement of a dispute agreed to before the date of issue of the Ruling.
Appendix 1 - Explanation
|This Appendix is provided as information to help you understand how the Commissioner's view has been reached. It does not form part of the binding public ruling.|
16. Tables A and B are periodically updated to incorporate further effective life determinations made by the Commissioner as a result of effective life reviews. We consult industry bodies and interested taxpayers during effective life reviews. In some instances, we use reports prepared by independent consultants. An independent review panel also checks each review process to confirm the level of industry consultation was appropriate. The panel typically comprises representatives from the Corporate Tax Association, Chartered Accountants Australia and New Zealand, Australian Finance Industry Association and the Australian Taxation Office.
17. The Commissioner has made a determination of the effective life of certain depreciating assets in Tables A and B to take effect from 1 July 2018. The Table A assets in the new determination are assets used in the following industries and industry activities:
- butter manufacturing
- fruit and vegetable processing
- gas, oil and mining support services (excluding offshore services)
- ice cream manufacturing
- scientific testing and analysis services
- spirit manufacturing.
19. The removal of assets from Tables A or B does not indicate that the Commissioner no longer considers them to be depreciating assets. In some cases, it is due to the difficulties in determining an appropriate effective life that accurately reflects all the facts and circumstances particular to that asset. In these cases, you need to work out its effective life yourself (see section 40-105 and paragraphs 46 to 49 of this Ruling).
20. An asset that is a depreciating asset for a particular taxpayer or industry may not necessarily be a depreciating asset for another taxpayer or industry. This is typically the case where the asset is an improvement to land. For example, effective lives have been determined for swimming pools in Table B. However, these effective life determinations only apply to the swimming pools that are used as plant in a business. A residential property owner cannot use these effective life determinations because a swimming pool used in a residential rental property setting is not plant (and not a depreciating asset) to which Division 40 applies.
How does the Commissioner determine the effective life of a depreciating asset?
21. The Commissioner makes a determination of the effective life of a depreciating asset by estimating the period (in years, including fractions of years) the asset can be used by any entity for a specified purpose. If relevant for the asset, the Commissioner:
- assumes it will be subject to wear and tear at a rate that is reasonable for the Commissioner to assume
- assumes it will be maintained in reasonably good order and condition, and
- has regard to the period within which it is likely to be scrapped, sold for no more than scrap value, or abandoned (see section 40-100).
22. In determining an effective life, the Commissioner considers the factors listed paragraph 23 of this Ruling. The list is not exhaustive. For example, in determining the effective life of horticultural plants, issues such as crop management techniques (crop regeneration and topworking or reworking where trees are cut back to the stump) were taken into account along with the listed factors. Where appropriate, each factor is considered based on historical information and future expectations. No single factor is necessarily conclusive and the relative importance of each varies depending on the asset.
- physical life
- manufacturing specifications and engineering information
- use of the asset in a particular industry
- use of the asset in different industries
- industry standards
- repairs and maintenance
- retention period
- scrapping or abandonment practices
- lease periods
- financial analysis, and
- market value.
25. An effective life determination is an estimate of the period the asset can be used by any entity for a specified purpose. Often an asset is not used for a specified purpose for the whole of its physical life. For example, an asset may be retired from use for a specified purpose but be retained as a source of spare parts. In this instance, the effective life ends when the asset is retired.
26. An asset's physical life can be seen as the outer limit of its effective life. This is a useful starting point for analysing the factors to be considered in determining the effective life of the asset.
Manufacturing specifications and engineering information
27. The effective life of a new asset cannot be based solely on evidence of past use of the asset. The current design may differ for various reasons including advances in technology and different construction materials. Analysing manufacturing specifications and engineering information for the new asset is important when estimating its effective life.
Use of the asset in a particular industry
Use of the asset in different industries
29. The use of an asset in different industries is another important factor. For example, using a car in the taxi industry would subject the car to more wear and tear than using a car in another industry. The effective life determined by the Commissioner in each industry would be different, reflecting that different use.
Repairs and maintenance
32. It might be suggested that the life of an asset can be extended indefinitely if there is unlimited expenditure on repairs and maintenance. However, paragraph 40-100(6)(b) requires the Commissioner to assume that an asset will be maintained only in reasonably good order and condition. Therefore, an asset's effective life is generally limited by the period it is economic to maintain the asset, even though it is still possible to continue repairs and maintenance to keep it operational.
33. An asset can be subject to such a level of repairs and maintenance that it has been wholly or substantially physically replaced. In those circumstances, the effective life of the asset is considered to have ended and a new asset to have come into place.
34. The effective life of an asset is the total period it can be used by any entity for a specified purpose. The retention period is the time a particular taxpayer expects to hold a depreciating asset for any purpose. For example, it is common practice in some businesses to dispose of a car after it has been driven a pre-determined number of kilometres. That would be the retention period for that taxpayer. The effective life of the car, however, would end only when the car cannot be used by any taxpayer for a specified purpose.
37. Commercial obsolescence may occur if demand for the goods produced by the asset stops because consumers choose not to buy them, or Government regulation affects market demand. It may also occur if the raw material the asset processes becomes unavailable.
38. Technological obsolescence may occur when technology advances and another asset becomes better suited for the relevant purpose for which an existing asset is used. Even so, an asset's effective life does not necessarily end with each technological advance. A taxpayer can still use an asset for a specified purpose even though a newer model exists.
39. There are two types of commercial and technological obsolescence: one can be predicted at the time the asset is first used and one is unpredictable and emerges later. Unpredictable obsolescence cannot be taken into account when estimating effective life. Predicted obsolescence would only be taken into account if it is expected with a high level of certainty across a majority of users.
40. Taxpayers faced with predicted obsolescence that would arise only because of their particular use of the asset may choose to work out the effective life of the asset themselves, rather than adopt the effective life determined by the Commissioner.
Scrapping or abandonment practices
41. Once a taxpayer has scrapped or abandoned an asset, it is presumed it can no longer be used by anyone for a specified purpose. The scrapping of an asset can demonstrate that the asset is either physically exhausted or obsolete. The abandonment of an asset can demonstrate that it is too difficult or costly to remove it from its place of operation.
43. Effective life is the period a depreciating asset can be used by any entity for a specified purpose, so it is unlikely that an asset would be leased for a period greater than its effective life. This generally suggests that the effective life of an asset is no shorter than the period it is leased.
44. As with lease periods, economic or financial analysis indicating the period over which an asset is intended for use suggests the effective life is no shorter than that period. In many instances, the analysis may only reflect the capital cost recovery period, or the term of a contract, when the asset may in fact be used for a specified purpose by any entity for a much longer time.
45. The defining character of a depreciating asset is that its market value actually falls, or is expected to fall, over time. Therefore, analysing the decline of market value of an asset class is important to the determination of the asset's effective life.
Working out your own effective life
46. The Commissioner only takes account of normal industry practice when estimating effective life. Taxpayers who choose to self-assess, however, can take account of their own particular circumstances of use (see section 40-105).
47. The Commissioner only makes determinations of the effective life of new assets. If you purchase a second-hand asset where its condition justifies a shorter life than that determined by the Commissioner, you can self-assess. A taxpayer who self-assesses the effective life of a depreciating asset acquired after 11.45 am, by legal time in the Australian Capital Territory on 21 September 1999 is no longer required to assume that it is new.
48. Taxpayers can recalculate the effective life of a depreciating asset if the effective life used is no longer relevant because of changed circumstances relating to the use of the asset (see section 40-110). An example could be an unpredicted obsolescence or more or less rigorous use than anticipated.
49. For some assets, you do not have a choice to work out the effective life yourself or use an effective life determined by the Commissioner. In addition, the effective life of these assets cannot be recalculated. The choice is not generally available:
- for most intangible depreciating assets (see subsection 40-95(7)) 
- if a depreciating asset was acquired from an associate who claimed, or could have claimed, deductions for the asset's decline in value (see subsection 40-95(4))
- for a depreciating asset that you started to hold but the user of the asset did not change or is an associate of the former user; for example, under a sale and leaseback arrangement (see subsection 40-95(5)), and
- if there has been rollover relief (see subsection 40-345(2)).
52. These conditions mean that not all shipping vessels listed under the Water transport and support services (48100 to 48200 and 52110 to 52190) sub-category in Table A will be eligible for the capped life at any given time.
53. For this reason, no shipping vessels have been marked with a hash (#) in the third column of Table A as would occur with other assets that have no additional eligibility requirements for a capped life.
Accelerated depreciation for primary producers
55. Primary producers can claim a deduction over three years for capital expenditure incurred at or after 7.30pm, by legal time in the Australian Capital Territory, on 12 May 2015 on the construction, manufacture, installation or acquisition of a fodder storage asset. The expenditure for the asset must have been incurred primarily and principally for use in a primary production business conducted on land in Australia. The asset is marked in Table A with a plus (+) in the third column.
56. No deduction is available for capital expenditure incurred for acquiring a second-hand fodder storage asset. However, if it can be shown that no one else has deducted or could deduct an amount, in any income year, for earlier capital expenditure on the construction, manufacture or previous acquisition of the asset, a deduction may be available.
Decline in value calculation
57. The effective life shown in Tables A or B is a component of the formula under which the decline in value of the depreciating asset is calculated. (See subsections 40-70(1) and 40-72(1) for diminishing value and subsection 40-75(1) for prime cost.)
New and reviewed effective lives
Important terms and definitions in Tables A and B
59. The terms 'freestanding' and 'fixed' describe certain residential rental property assets listed in Table A. 'Freestanding' is also used in Table B for 'light fittings and freestanding lights'. For the purposes of the determination of the effective life of such assets, the terms have the following meanings:
Freestanding - are items designed to be portable or movable; any attachment to the premises is only for the item's temporary stability.
Fixed - are items annexed or attached by any means (for example screws, nails, bolts, glue, adhesive, grout or cement) but not merely for temporary stability.
60. The terms 'environmental control structure' and 'protective structure' are used to describe certain agricultural assets listed in Table A. For the determination of effective life of such assets, the terms have the following meanings:
Environmental control structure - is a structure designed to provide a protective environment within which the operator is able to monitor and manipulate factors influencing the growing environment. This includes factors such as temperature, humidity, air movement, light, water and pests to enable the greatest efficiency in producing the desired product.
Protective structure - is a structure used primarily and principally for protecting a growing product from one or more natural elements such as sun, hail, birds and wind.
Including or includes - when an entry is described as 'including' or 'includes' other items, these other items are separate assets, each with the same effective life. For example, the entry 'Refrigeration assets (including chillers, compressors, condensers, evaporative coolers and pumps)' indicates that chillers, compressors, condensers, evaporative coolers and pumps are separate assets within the class of refrigeration assets, all of which have the specified effective life.
Incorporating - when an entry is described as 'incorporating' other items, these other items are not separate assets but are merely components of the one single asset being described. For example, the entry 'Conveyor systems (incorporating structures, belts, gearboxes and motors)' indicates that the structure, belts, gearboxes and motors are components of the one asset, the conveyor system.
Hire car - is a passenger car hired with a driver, not being a taxi.
Rental car - is a passenger car hired, leased or rented for short-term use without a driver.
Appendix 2 - Detailed contents list
|Summary - what this Ruling is about||1|
|Effective life determination||6|
|Effective life applicable||8|
|How to use Tables A and B||10|
|Date of effect||14|
|Appendix 1 - Explanation||15|
|How does the Commissioner determine the effective life of a depreciating asset?||21|
|Manufacturing specifications/Engineering information||27|
|Use of the asset in a particular industry||28|
|Use of the asset in different industries||29|
|Repairs and maintenance||32|
|Scrapping or abandonment practices||41|
|Working out your own effective life||46|
|Accelerated depreciation for primary producers||55|
|Decline in value calculation||57|
|New and reviewed effective lives||58|
|Important terms and definitions in Tables A and B||59|
|Appendix 2 - Detailed contents list||63|
|Schedule - ANZSIC categories in Table A||Page 15|
|Schedule - Table A as at 1 July 2018||Page 20|
|Schedule - Table B as at 1 July 2018||Page 260|
You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).
ANZSIC categories in Table A
|AGRICULTURE, FORESTRY AND FISHING (01110 to 05290)||20|
|Beef cattle farming||32|
|Beef cattle feedlots||32|
|Coffee, olive and tree nut growing||30|
|Dairy cattle farming||33|
|Forestry and logging||40|
|Nursery and floriculture production||25|
|Other agriculture and fishing support services||41|
|Poultry farming for breeding, eggs and meat||35|
|Vegetable growing (under cover)||27|
|Vegetable growing (outdoors) and sugar cane growing||28|
|MINING (06000 to 10900)||42|
|Construction material mining||52|
|Gold ore mining||51|
|Iron ore mining||50|
|Mineral sand mining||51|
|Mineral exploration services||53|
|Nickel ore mining||52|
|Oil and gas extraction||47|
|Other mining support services||54|
|Petroleum exploration services||53|
|MANUFACTURING (11110 to 25990)||56|
|Bakery product manufacturing||80|
|Bakery product manufacturing (non-factory based)||81|
|Basic chemical and chemical product manufacturing||120|
|Beer manufacturing (except non-alcoholic beer)||100|
|Boiler, tank and other heavy gauge metal container manufacturing||164|
|Ceramic product manufacturing||135|
|Cereal and pasta product manufacturing||78|
|Cleaning compound and toiletry preparation manufacturing||128|
|Concrete product manufacturing||140|
|Cured meat and smallgoods manufacturing||62|
|Dairy product manufacturing||64|
|Fabricated metal product manufacturing||160|
|Fruit and vegetable processing||68|
|Furniture and other manufacturing||175|
|Glass and glass product manufacturing||133|
|Grain mill product manufacturing||75|
|Human pharmaceutical and medicinal product manufacturing||127|
|Industrial gas manufacturing||116|
|Iron smelting and steel manufacturing||144|
|Log sawmilling and timber dressing||106|
|Motor vehicle body and trailer manufacturing||172|
|Motor vehicle manufacturing||164|
|Non-ferrous metal casting||159|
|Non-metallic mineral product manufacturing||132|
|Oil and fat manufacturing||73|
|Other basic chemical product manufacturing||128|
|Other food product manufacturing n.e.c.||91|
|Other motor vehicle parts manufacturing||172|
|Other professional and scientific equipment manufacturing n.e.c.||175|
|Other transport equipment manufacturing n.e.c.||174|
|Other wood product manufacturing||107|
|Paint and coatings manufacturing||131|
|Paper stationery manufacturing||110|
|Photographic, optical and ophthalmic equipment manufacturing||174|
|Plaster product manufacturing||138|
|Plywood and veneer manufacturing||108|
|Polymer film and sheet packaging material manufacturing||129|
|Polymer product and rubber product manufacturing||131|
|Prepared animal and bird feed manufacturing||87|
|Printing support services||113|
|Pulp, paper and converted paper product manufacturing||109|
|Railway rolling stock manufacturing and repair services||172|
|Ready-mixed concrete manufacturing||139|
|Reconstituted wood product manufacturing||108|
|Rigid and semi-rigid polymer product manufacturing||129|
|Sanitary paper product manufacturing||110|
|Soft drink, cordial and syrup manufacturing||98|
|Steel coil roll forming, slitting, blanking and sheet metal forming||160|
|Textile, leather, clothing and footwear manufacturing||105|
|Wine and other alcoholic beverage manufacturing||103|
|ELECTRICITY, GAS, WATER AND WASTE SERVICES (26110 to 29220)||175|
|Sewerage and drainage services||182|
|Solid waste collection services||184|
|Waste remediation and materials recovery services||186|
|Waste treatment and disposal services||185|
|CONSTRUCTION (30110 to 32990)||187|
|Other heavy and civil engineering construction n.e.c.||189|
|WHOLESALE TRADE (33110 to 38000)||189|
|Petroleum product wholesaling||189|
|RETAIL TRADE (39110 to 43209)||191|
|Motor vehicle tyre or tube retailing||192|
|Other store-based retailing||195|
|ACCOMMODATION AND FOOD SERVICES (44000 to 45302)||195|
|Cafes, restaurants, takeaway food services, pubs, taverns bars and clubs (hospitality)||197|
|TRANSPORT POSTAL AND WAREHOUSING (46100 to 53090)||198|
|Other air and space transport||205|
|Airport operations and other air transport support services||208|
|Courier pick-up and delivery services||208|
|Other transport n.e.c.||206|
|Other transport support services n.e.c.||210|
|Other warehousing and storage services||210|
|Rail freight and passenger transport services||200|
|Scenic and sightseeing transport||205|
|Tramway and light rail passenger transport services||199|
|Water transport and support services||202|
|INFORMATION MEDIA AND TELECOMMUNICATIONS (54110 to 60200)||211|
|Electronic information storage services||220|
|Internet publishing and broadcasting||218|
|Library and other information services||220|
|Motion picture and video activities||211|
|Motion picture exhibition||214|
|FINANCIAL AND INSURANCE SERVICES (62100 to 64200)||221|
|RENTAL, HIRING AND REAL ESTATE SERVICES (66110 to 67200)||221|
|Non-residential property operators||228|
|Rental and hiring services (except real estate)||221|
|Residential property operators||224|
|PROFESSIONAL, SCIENTIFIC AND TECHNICAL SERVICES (69100 to 70000)||229|
|Professional photographic services||233|
|Scientific research services||229|
|Scientific testing and analysis services||231|
|Surveying and mapping services||230|
|ADMINISTRATIVE AND SUPPORT SERVICES (72110 to 73200)||234|
|Building and other industrial cleaning services||234|
|EDUCATION AND TRAINING (80100 to 82200)||237|
|HEALTH CARE AND SOCIAL ASSISTANCE (84010 to 87900)||237|
|Nursing home operation||244|
|Optometry and optical dispensing||242|
|Pathology and diagnostic imaging services||240|
|Specialist medical services n.e.c.||239|
|ARTS AND RECREATION SERVICES (89100 to 92099)||245|
|Creative and performing arts activities||245|
|Health and fitness centres and gymnasia operation||245|
|Sport and recreation services||246|
|OTHER SERVICES (94110 to 96030)||248|
|Automotive body, paint and interior repair n.e.c.||251|
|Automotive repair and maintenance||248|
|Funeral, crematorium and cemetery services||257|
|Hairdressing and beauty services||256|
|Laundry and dry cleaning services||257|
|Other machinery and equipment repair and maintenance||252|
|Photographic film processing||258|
Commissioner of Taxation
27 June 2018
ITAA 1997 Div 40
ITAA 1997 40-25
ITAA 1997 40-70(1)
ITAA 1997 40-72(1)
ITAA 1997 40-75(1)
ITAA 1997 40-95
ITAA 1997 40-95(4)
ITAA 1997 40-95(5)
ITAA 1997 40-95(7)
ITAA 1997 40-100
ITAA 1997 40-100(5)
ITAA 1997 40-100(6)(b)
ITAA 1997 40-102
ITAA 1997 40-102(4)
ITAA 1997 40-102(4A)
ITAA 1997 40-105
ITAA 1997 40-110
ITAA 1997 40-345(2)