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Edited version of private advice

Authorisation Number: 1051802649044

Date of advice: 17 March 2021

Ruling

Subject: Am I in business - active asset - small business CGT concession

Question 1

Was the taxpayer carrying on a business of providing short-term holiday accommodation from the properties located at XX?

Answer

No

Question 2

Are the properties active assets under Subdivision 152-A of the Income Tax Assessment Act 1997 (ITAA 1997)?

Answer

No

This ruling applies for the following period:

Financial year ending 30 June 20XX

The scheme commences on:

1 July 20XX

Relevant facts and circumstances

The corporate trustee of the trust, XX Pty Ltd held 3 properties, which were used for short-term accommodation activities (the activities).

Mrs XX and Mr XX are the beneficiaries of the trust and the directors of the corporate trustee.

Appendix X of the private ruling application provides

•         The 3 properties are known as

-        XX Street, XX,

-        XX Street, XX,

-        XX Street, XX.

•         The properties have been used by the activities since 200X. Mrs XX and Mr XX did not have other employments since 200X.

•         The properties have never been used for private purposes.

•         One property, XX St, was disposed on XX 201X.

•         The activities registered with the XX Information Centre, established a website for advertising (the website).

•         The activities have been operated seven days a week. There is no limit on the bookings but more than 90% of bookings are for durations of 3 days or less.

•         Bookings are available any time via Mrs XX and Mr XX's contact details stated on the website and stated in front of the properties.

•         The payment policy is for guests to pay in full on arrival through the EFTPOS machine at the premises.

•         Terms and conditions in relation to payment, bookings and cancellations, rules during stay are listed on the website.

•         The business activities include:

-        Reception services;

-        Bathroom cleaning, kitchen cleaning, laundering and gardening;

-        Room services;

-        Emergency assistance for guests.

Appendix X of the private ruling application provides a Profit & Loss statement, which covers the 201X and 201X financial years.

Appendix X of the private ruling application added 'supporting information' for each of the property.

•         All the 3 properties were purchased in the 19X0s.

•         One property was seasonally booked as short-term accommodation if requested and the other two properties were not always for short-term holiday accommodation, prior to 200X.

•         Terms and Conditions for the use of the property by visitors during their stay provided on the business website

•         All properties are cleaned after being occupied and can be cleaned on a daily basis as and when required.

•         No additional charges requested for extra cleaning.

•         Daily accommodation and services management of the properties carried out by Mrs XX and Mr XX include but not limited to: (the 9 tasks)

                 i.        Taking calls for booking and arranging accommodation;

                ii.        Meeting and greeting all guests;

               iii.        Attending to general housekeeping needs and queries of guests;

               iv.        Bathrooms cleaning, include replacing towels, soaps, toilet rolls, shampoo/conditioners and hand wash liquid after being occupied or as required;

                v.        Kitchen cleaning for refrigerator, stove, crockery, cutlery and glasses. Vacuuming and mopping all floors. Replacing coffees, teas, sugars, milks and water bottles;

               vi.        Laundering and ironing for bedding, towels, tea towels;

              vii.        Cleaning of exterior gardens, pathways and verandah and other general gardening when required;

             viii.        Room services and meals can be provided when ordered or requested;

               ix.        Emergency assistance for guests (24/7).

•         The Trust maintains a separate bank account for the activities.

When the Commissioner requested additional information, the below clarifications, 2 balance sheets and an accommodation booking ledger sample (booking sample) were provided

•         Prior to 200X, during non-peak holiday seasons, the properties were available for overnight and short term stays while renovations and repairs were undertaken to keep the properties in good condition and ready for the upcoming peak season.

•         One property comprises 2 rentable units.

•         Another property also comprises 2 rentable units, known as unit 1 and unit 2.

•         The main form of advertising is via the website together with local information and Tourism centres.

•         There is no formal reception area in any of the relevant property. The guests usually phone on arrival. Mrs XX and Mr XX meet the guests on site, provide a tour of the facilities, outline the terms and conditions of the stay and attend to any questions or queries the guests may have in relation to their stay.

•         Mrs XX and Mr XX did not engage contractors/third parties to undertake 'the 9 tasks'; they are generally undertaken and completed by Mrs XX and Mr XX personally. They would involve Mrs XX and Mr XX working at least 7 hours a day on average to attend for all properties. In addition to 'the 9 tasks', Mrs XX and Mr XX would also attend to maintaining and managing the books and records of the business including preparing and lodging Business Activity Statements and managing finances.

•         Generally Mrs XX and Mr XX organise the meals with breakfast packs available to guests. Breakfast is the major meal requested by guests; generally other meals such as lunch and dinner are organised by guests separately.

•         When the activities commenced, Mrs XX and Mr XX strategically planned the set-up of it at that point in time. The business has been operating for more than 1X years, the initial business plan has been superseded by virtue of the fact that the business is established and has been operating successfully for an extended period of time. (the initial business plan was not provided).

•         No council approval required by local council to carry on accommodation business activities. The trustee held business insurance policy for operation of the B&B business. The class of cover is specifically a B&B Insurance policy.

•         After the sale one property, the trust continued to operate the short-term accommodation activities in a similar manner with the remaining two properties.

The booking sample provided is for XX Street (unit 1 and unit 2) for the period from XX 201X to XX 201X, in which the Commissioner found that

•         Between XX to XX 201X, 3 counts of cleaning (for properties) were recorded, in which 2 counts were for unit 1 and 1 count was for unit 2. All the 3 counts of cleanings appear consistent with a pattern that a property was cleaned at a point after being occupied for a booking and before the occupancy of the following booking.

•         There is no additional cleaning recorded in the sample period.

•         Within the sample period, unit 2 had X bookings, in which at least X were for 7 nights or more.

•         Within the sample period, unit 1 had X bookings, in which X were for 7 nights and X was for 4 nights.

After the consideration on the further information provided,

•         The Commissioner found the state government's website provides:

accommodation businesses covered by the Prescribed Accommodation Regulations are:

-        bed and breakfasts accommodating more than five people

-        hotels and motels

-        guesthouses and boutique hotels

-        self-contained accommodation

-        farm stays.

The Commissioner found that at least one property is capable of accommodating 5 people or more, pursuant to the website information. The Commissioner therefore considers that a business covered by the Prescribed Accommodation Regulations would require a council permission, therefore asked for an explanation. The explanation provided confirmed that the local council has never required or requested Mrs XX and Mr XX to register their business

•         When the Commissioner requested clarifications regarding some details contained in the Terms and Conditions, it's been explained (on XX 202X) that

-        the Terms and Conditions are no longer used or relevant to guests and need to be removed accordingly; they have not been used for over 1X years.

-        XX, the person listed in the Terms and Conditions as a contact person for guests' clarification enquiries regarding the Terms and Conditions and for urgent after-hours assistance, is Mrs XX and Mr XX's family relative, who assisted in the initial setting-up of the business, but has not been involved in working in the business for 1X+ years.

-        While there is a signature section contained in the Terms and Conditions, it was claimed that guests are not and do not sign Terms and Conditions, or any other legal documents.

On the other hand, the Commissioner found that the Terms and Conditions remain accessible on the website as of XX 202X.

Based on the information available to the Commissioner,

•         The activities registered for Goods & Services Tax (GST). The GST was deregistered on XX 201X. The Business Activity Statements (BAS) were lodged till the deregistration of the GST.

It's been claimed that the reason for the deregistration of GST is, after the disposal of 1 property, the income is estimated to be less than the GST threshold $75,000.

According to the relevant tax return information,

•         Between 20XX and 20XX financial years, the activities made tax losses in most of the years (the loss years). The tax losses were carried forward to the XX, XX financial years (the later years), where the activities made profits of XX, XX respectively. The profits got offset by the carried forward losses to nil in each of the later years.

It's been stated that in 20XX and prior years, Mrs XX and Mr XX drew remuneration in the form of salary and wages form the activities.

It is further provided that the properties were not recognised as 'eligible residential arrangements' by state government for 20XX Coronavirus Land Tax Relief purpose.

Relevant legislative provisions

Income Tax Assessment Act 1997 Section 6-5

Income Tax Assessment Act 1997 Section 8-1

Income Tax Assessment Act 1997 Subdivision 152-A

Income Tax Assessment Act 1997 Section 152-35

Income Tax Assessment Act 1997 Section 152-40

Income Tax Assessment Act 1997 Section 152-205

Income Tax Assessment Act 1997 Section 995-1

Reasons for decision

Question 1

Are you carrying on a business?

Section 995-1 of the ITAA 1997defines 'business' as 'including any profession, trade, employment, vocation or calling, but not occupation as an employee'.

The question of whether you are carrying on a business is a question of fact and degree. There are no rigid rules for determining whether the activity amounts to the carrying on of a business. The facts of each case must be examined. In Martin v FC of T (1953) 90 CLR 470 at 474; 5 AITR 548 at 551, Webb J said:

The test is both subjective and objective; it is made by regarding the nature and extent of the activities under review, as well as the purpose of the individual engaging in them, and, as counsel for the taxpayer put it, the determination is eventually based on the large or general impression gained.

However, the courts have developed a series of indicators that can be applied to determine whether you are carrying on a business.

Taxation Ruling TR 97/11 (TR 97/11) provides the indicators established by the courts that need to be considered when determining whether a business is being carried on. It should be noted that TR 97/11 specifically deals with carrying on a business of primary production but the indicators established can be equally applied to most other activities. Paragraph 13 of TR 97/11 states that the following indicators are relevant:

Paragraph 15 of TR 97/11 states that no one indicator is decisive (Evans v. FC of T 89 ATC 4540; (1989) 20 ATR 922). In addition, paragraph 16 of TR 97/11 states that the indicators must be considered in combination and as a whole. Whether a business is being carried on depends on the general impression gainedfrom looking at all the indicators (Martin v. Federal Commissioner of Taxation (1953) 90 CLR 470 at 474; 5 AITR 548 at 551), and whether these factors provide the operations with a 'commercial flavour' (Ferguson v. Commissioner of Taxation (1979) 37 FLR 310 at 325; 79 ATC 4261 at 4271; (1979) 9 ATR 873 at 884).

Taxation Ruling IT 2423 states at paragraph 5:

A conclusion that an individual is carrying on a business of letting property would depend largely upon the scale of operations. An individual who derives income from the rent of one or two residential properties would not normally be thought of as carrying on a business. On the other hand if rent was derived from a number of properties or from a block of apartments, that may indicate the existence of a business.

As a general rule, to be carrying on a business of letting rental properties the size and scale of the activity must be significantly larger than that of a business of providing short term accommodation with a significant degree of services. To be clear, one or two properties will not be sufficient. A number closer to 20 or an entire block of apartments it closer to the number required to characterise the activity as a business of letting rental properties.

The issue of whether the owner of one or several properties, in providing accommodation, is carrying on a business has arisen in a number of cases.

In Commissioner of Taxation v. McDonald (1987) 15 FCR 172; 18 ATR 957; 87 ATC 4541 (McDonalds Case), the taxpayer and his wife owned two properties, one of which was let on a short term basis to holiday makers, which were subsequently let through letting agents. The Federal Court considered that for a business to be carried on by owners of property, one would expect that they would be involved in providing services in addition to the process of letting property (as with a boarding house), not merely receiving payments for the tenants occupation of the property. It was considered that this was not a case of the active joint participation of parties in a business activity.

In Carson & Anor v FC of T [2008] AATA 156 (Carson's Case) the taxpayers owned one property jointly which was used to provide short term tourist accommodation, usually for stays of about a week to two weeks. Senior Member BH Pascoe stated that whether a business is being carried on, is a question of fact and an objective consideration of the extent of the applicants' activities relating to the property. He pointed out that appointing a real estate agent to arrange rentals and minor repairs, spending one week every six months servicing the property and provided brochures relating to the property as required are activities with all the earmarks of maintaining and deriving income from an investment rather than the carrying on of a business. Similarly, activities such as financing the property, dealing with rating authorities and body corporate are no more than any investor in real estate would do.

In Case G10 75 ATC 33 (Case G10), the taxpayer owned two properties of which six units were let as holiday flats for short term rental. The taxpayer, with assistance from his wife, managed and maintained the flats. Services included providing furniture, blankets, crockery, cutlery, pots and pans, hiring linen and laundering of blankets and bedspreads. The taxpayer also showed visiting inquirers over the premises, attended to the cleaning of the flats on a daily basis, mowing and trimming of lawns, and various other repairs and maintenance. The taxpayer's task in managing the flats was a seven day a week activity. The Board of Review held that the activity constituted the carrying on of a business.

Application to your situation

We have taken the following into consideration when determining whether the Trust is carrying on a business in relation to the use of the properties for short-term accommodation:

Significant commercial purpose

This indicator is closely linked to the others and is a generalisation drawn from the interaction between them. It is particularly linked to the size and scale of activity, the repetition and regularity of activity and the profit indicators.

Intention of the taxpayer

It is stated that the reason for the purchases of the properties, at the time of purchase, was for 'Bed and Breakfast' business.

The properties have never been used for private purposes.

In addition, renovations and repairs were undertaken to keep the properties in good condition for short-term accommodation purposes.

Prospect of profits

The taxpayer's involvement in the business activity should be motivated by wanting to make a tax profit and the taxpayer's activities should be conducted in a way that facilitates this. This will require examining whether objectively there is a real prospect of making a profit from participating in the business of the taxpayer.

In this case, between 20XX and 20XX financial years, the activities made tax losses in most of the years. Although the activities reported net profits in the later years, it appears that the profits were achieve under the situation that Mrs XX and Mr XX no longer drew salary and wages from the activities. In addition, the trust did not make trust distributions to Mrs XX or Mr XX in the later years as the profits were offset by prior years' carried forward losses to nil.

These can be seen as indicators of lower degree of prospect for profits, not significantly in excess of the profit prospect of investment/rental properties, in the past years. Further, the fact that 1 of the properties was disposed in 20XX did not demonstrate a higher profit prospect. It in contrast can be regarded as a reduction in the profit prospect for 20XX financial year and the future years.

Repetition and regularity

Frequent and regular transactions are the usual feature of business operations. Turnover is maximised if the processes are repeated over a long period. Frequent activity does not necessarily mean a business is carried on but it will support this argument (FC of T v. Radnor 91 ATC 4689; 22 ATR 344).

Based on the information provided, the short-term accommodation properties were regularly booked. However, while it's been claimed that Mrs XX and Mr XX regularly performed duties for at least 7 hours a day on average, some of such duties may not have been performed at the claimed level of regularity or were performed by others, such as

Activities of the same kind and carried on in a similar manner to those of the ordinary trade in that line of business

If a taxpayer carries out their activity in a manner similar to other taxpayers in the industry, it is more likely that their activity amounts to the carrying on of a business. That is, the taxpayer's operations are of the same kind and carried on in the same way as those characteristic of ordinary trading in that particular line of business (IR Commissioners v. Livingston 11 TC 538).

This indicator requires a comparison between the activities of the taxpayer in question and those undertaken by a person in business in the same type of industry. Where the taxpayer's activities are similar in nature to the business, further support is given to the fact that a business exists.

The 3 properties were not rented out on a long-term residential basis but were used for short-term accommodation. However, the Commissioner is of the view that the level of services provided by Mrs XX and Mr XX, as suggested by the Terms and Conditions and evidenced by the booking sample, did not reach the extent of a motel or hotel level accommodation.

Organisation in a business-like manner, the keeping of books, records and the use of a system

The activities conducted by, or on behalf of the taxpayer, should be carried out in a systematic and organised manner. This will usually involve matters such as the keeping of appropriate business records by the taxpayer. If the activities are carried out on the taxpayer's behalf by someone else, there should be regular reports provided to the taxpayer on the results of those activities.

It's been claimed that Mrs XX and Mr XX attended to maintaining and managing the books and records of the activities. The activities can be regarded as managed in a systematic manner for bookkeeping and taxation reporting.

On the other hand, the Commissioner does not believe that the accommodation activities were carried out at the claimed level of business-like manner, as

The size and scale of the activity

The larger the scale of the activity the more likely it is that the taxpayer is carrying on a business. This is not conclusive and a person may carry on a business in a small way (Thomas v. FC of T 72 ATC 4094; 3 ATR 165).

The size and scale of the short-term accommodation activities of this case is considered small for the number of properties (3 properties with maximum of 5 rentable units) that were used for the activities. Furthermore, there is no indication that the short-term accommodation activities will be expanded. In contrast, with 1 property disposed in 20XX, the scale reduced to 2 properties (with maximum of 4 rentable units) for the remaining of the 20XX financial year and the following years.

Hobby or recreation

The short-term accommodation activities do not have the nature of a hobby or recreational pursuit.

Conclusion

The number of the properties used by the short-term accommodation activities is not viewed as being of a size or scale necessary to be characterised as carrying on a business of letting rental properties. Therefore, whether the Trust's activities amount to the carrying on of a business should be determined by the level of services provided to the guests and other factors.

In this case, although it was contended that the Terms and Conditions are outdated and no longer used, the Commissioner takes the view that it remains accessible to its potential guests on the website as of X 20XX, it therefore remains relevant for consideration.

While the Terms and Conditions and the booking sample do not suggest a service level that goes beyond of letting short-term rental properties, along with the consideration on factors like the small size and scale, lower degree of the business-like manner and the lower prospect of profits, the activities are not viewed as carrying on a business.

Under a conclusion that the activities did not constitute carrying on a business, the Small Business CGT concession is not applicable.

Question 2

Active asset

For completeness, the Commissioner further analysed the scenario if the activities were viewed as carrying on a business, and the trust was a Small Business Entity. Under this assumption, the requirements of an active asset set out in Subdivision 152-A of the ITAA 1997 should be examined.

For a capital gains tax (CGT) asset of a business to be an active asset for the purposes of Subdivision 152-A of the ITAA 1997, it must firstly satisfy one of the 'positive tests' in subsection 152-40(1) of the ITAA 1997, and then also not be excluded by one of the exceptions in subsection 152-40(4) of the ITAA 1997.

Under paragraph 152-40(1)(a) of the ITAA 1997 a CGT asset is an active asset (subject to the exclusions) if it is owned and used or held ready for use in the course of carrying on a business.

However, paragraph 152-40(4)(e) of the ITAA 1997 provides that an asset whose main use in the course of carrying on the business is to derive rent cannot be an active asset (unless that main use was only temporary). That is, even if the asset is used in a business it will not be an active asset if its main use is to derive rent.

Taxation Determination TD 2006/78 (TD 2006/78) discusses the circumstances in which a premises used in a business of providing accommodation for reward may satisfy the active asset test, notwithstanding the exclusion mentioned above.

Whether an asset's main use is to derive rent will depend upon the particular circumstances of each case. In accordance with paragraph 22 of TD 2006/78, the term 'rent' has been described as follows:

If residential units are operated as holiday apartments, the issue arises as to whether the occupants of the apartments are tenants/lessees or only have licenses to occupy. Paragraph 25 of TD 2006/78 states that ultimately this is a question of fact that depends on all of the circumstances involved. Relevant factors to consider in determining this question include:

whether the occupier as a right to exclusive possession (Radaich v. Smith (1959) 101 CLR 209),

the degree of control retained by the owner, and

the extent of any services provided by the owner such as room cleaning, provision of meals, supply of linen and shared amenities (Allen v. Aller (1966) 1 NSWR 572, Appah v. Parncliffe Investments Ltd [1964] 1 All ER 838 and Marchant v. Chaters [1977] 3 All ER 918).

If premises are leased to a tenant under a lease agreement granting exclusive possession, the payments involved are likely to be rent and the premises will not be an active asset. On the other hand, if the arrangement allows the person only to enter and use the premises for certain purposes and does not amount to a lease granting exclusive possession, the payments involved are unlikely to be rent.

Many arrangements involving holiday apartments are unlikely to be active assets because no business is being carried on or, even if a business is being carried on, it amounts to the derivation of rent. This is because in many cases the services provided are not sufficient to change the nature of the income from passive to active. For example if meals and/or daily cleaning are not provided.

In Carson & Anor v FC of T [2008] AATA 156, the Administrative Appeals Tribunal (AAT) considered this issue in relation to holiday rentals and stated:

In this matter, the subject asset is one unit, presumably within a group of residential units. Occupants generally stay for one or two weeks. Crockery, cutlery and linen are included but cleaning is done only after the occupants depart. I have no doubt that the occupants regard themselves as having "rented" the unit for the period of their stay and during that stay have exclusive possession. Unsurprisingly, no formal lease agreement is signed but this does not mean that there is no landlord/tenant relationship. On the facts provided, I am of the opinion that the main use of the subject property is to derive rent and, therefore, it is excluded from being an active asset under s 152-40(4) of the Act...

The AAT ruled that the main use of the property was to derive rent and therefore it was excluded from being an active asset. A key factor noted in Taxation Determination TD 2006/78 in determining whether the section 152-40(4) of the ITAA 1997 applied was whether the occupier had the right to exclusive possession or only a licence to occupy. Although no formal agreement was signed, there was a landlord/tenant relationship.

The AAT also ruled that the taxpayers' activities had all the earmarks of maintaining and deriving income from an investment rather than carrying on a business. The taxpayers' activities in respect to the property were adjudged to be no more than any investor in real estate would do. They were not the sustained, repetitive, commercial activities representing the carrying on of a business activity.

Application to your situation

It's been contended in the ruling application that no exclusive possession is granted to the guests as

...

the guests staying in the Properties do not have the right to sub-lease the Properties to a third party and should only use the Properties within terms and conditions agreed between the guests and the Trust.

Under the terms and conditions agreed between the guests and the Trust, all holiday accommodation must only be used for private, residential usage only and to accommodate the number of guests stated on your Booking Confirmation. No functions or parties may be conducted at the Property under any circumstances. Exceeding the stated number of guests will result in a termination of your stay without a refund. Charges for additional guests will be debited to your Credit Card without further notice.

...

The Commissioner noted that the above contention also refers to 'Terms and Conditions' in the first paragraph, and terms in the second paragraph appear identical to the ones in the Terms and Conditions on the website. The Commissioner again does not believe that it is reasonable to conclude that the Terms and Conditions on the website are no longer relevant.

-        The Terms and conditions states 'please call prior to the stay to discuss arrangements for keys to be collected and returned' - this aligns with the actions that a tenant under a residential lease agreement would normally be required to take: arranging for the key handover when lease commences and return the key at the point that the lease ends.

-        The Terms and conditions states 'All properties are leased on the understanding that tenants will treat the property with the same respect as their own home. Please leave the premises in the same good condition you found it...and report any damages...' - this also appears in line with a residential lease arrangement, where tenants are required to maintain the premises in their initial good condition, which may involve tenants' cleaning before lease ends.

-        Mrs XX and Mr XX did not reside in a room of one property while providing remaining rooms of the same property for guests' occupancy.

-        As suggested by the Terms and Conditions that tenants are required to maintain the premises in their initial good condition and report any damages, along with the reason that no 'daily' cleaning was recorded on the booking sample, the Commissioner believes that it is less likely for Mrs XX and Mr XX to enter a property before the end of an occupancy.

-        As discussed above, the Commissioner believes that it is less likely for Mrs XX and Mr XX to enter a property for maintenance or cleaning before the end of an occupancy.

-        The Commissioner does not believe the contention that Mrs XX and Mr XX retained a separate set of keys to the properties differentiates it from a residential lease, as the landlord of a residential lease would also normally retain a separate set of keys to the property.

-        The Terms and Conditions provide that all properties are self-contained. There is insufficient evidence that the degree of control retained by the trust exceeded the degree of control by the guests staying in the properties.

-        As discussed earlier, the Commissioner believes that it is more likely that the properties were only cleaned after each occupancy, at a level lower than the claimed level that they can be cleaned on a daily basis as and when required.

-        It's been clarified that Mrs XX and Mr XX mainly made breakfast packs available to guests; generally other meals such as lunch and dinner are organised by guests - the Commissioner believes that this level of service, without full breakfast, lunch or dinner, can be distinguished from cooking/preparing meals and providing for guests' enjoyment, regardless formal dining facilities are available or not.

-        The Terms and Conditions provide all properties have linen supplied and are self-contained. There are small quantities of washing powder, detergents, soap and toilet paper, however it is expected that you will need to bring supplies depending on our length of stay. - this is another indicator of lower level service provided to guests.

Conclusion

Even if held the short-term accommodation activities carrying on a business, and the trust was a Small Business Entity, the main or only use of the properties is considered deriving rent income. The properties are therefore excluded from being an active asset under paragraph 152-40(4)(e) of the ITAA 1997. As the properties do not meet the basic conditions set out in section 152-10 of the ITAA 1997, they are not entitled to the small business CGT concessions

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