Income tax: what is the opening value of a unit of property, for the purposes of calculating depreciation, if the unit was previously used for purposes other than producing assessable income?
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FOI status:may be releasedFOI number: I 1213126
|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, the Determination applies to transactions entered into both before and after its date of issue.|
1. The opening value of a unit is its original cost to the taxpayer less the amount of any depreciation that would have been allowed if the unit had been used to produce assessable income: section 61 of the Income Tax Assessment Act 1936 and FC of T v. Anderson (1956) 11 ATD 115; 6 ATR 324.
- a previously tax exempt entity becomes assessable, or plant that was previously used in the production of exempt income is used in the production of assessable income, or
- plant or articles are held for private purposes before being used in producing assessable income, or
- plant was previously used in the production of income that was not assessable.
Commissioner of Taxation
20 August 1992
NO ADVC 1318(MEL)
notional depreciated value
FC of T v Anderson
(1956) 11 ATD 115
6 ATR 324