Taxation Determination
TD 93/24
Income tax: is a deduction allowable for capital expenditure (subject to a valid section 124AB notice) under section 124ADG if the taxpayer does not have a petroleum field or proposed petroleum field?
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FOI status:
may be releasedFOI number: I 1214115| This Determination, to the extent that it is capable of being a 'public ruling' in terms of Part IVAAA of the Taxation Administration Act 1953 , is a public ruling for the purposes of that Part. Taxation Ruling TR 92/1 explains when a Determination is a public ruling and how it is binding on the Commissioner. Unless otherwise stated, this Determination applies to years commencing both before and after its date of issue. However, this Determination 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 Determination (see paragraphs 21 and 22 of Taxation Ruling TR 92/20). |
1. No. A deduction for capital expenditure is not allowable under section 124ADG where no petroleum field or proposed petroleum field exists. Subsection 124ADG(3) requires that there be a comparison made between 10 years, reduced by the number of years a deduction has already been allowed, and the estimated life of the field or the proposed field.
Commissioner of Taxation
11 February 1993
Previously issued as Draft TD 92/D233.
References
ATO references:
NO NORB J36/355/1
Subject References:
Allowable expenditure;
Petroleum prospecting
Legislative References:
ITAA 124ADG
| Date: | Version: | Change: | |
| You are here | 11 February 1993 | Original ruling | |
| 6 August 1997 | Withdrawn |