Is it eligible?

Prototypes, tooling and the R&D Tax Incentive

Sometimes eligible

Sometimes. A prototype is part of a core activity when it is the variant being tested, built only as far as the test needs. A rig built only so experiments can run is usually supporting, unless its own design is tested. Production tooling and demonstration units are not R&D, and tools held as assets usually go through decline in value.

Reviewed by George WalchFacts last verified

When it qualifies

A printed mould insert with conformal cooling

An illustrative company moulds a thick-walled polymer housing and wants to cut cycle time without warping the part. It prints a metal mould insert with cooling channels that follow the cavity, and its search found no data linking channel geometry to warpage in this polymer at this wall thickness. Each insert design is the variant under test. Designing and printing the inserts to the extent needed, and the press trials measuring cycle time and warpage, are core work.

When it does not

Production tooling and an assembly jig for a settled design

Once a design is chosen, the same company commissions a hardened production mould and builds an assembly jig for a customer's existing enclosure from the customer's drawings. Nothing is being tested: the mould reproduces a proven design and the jig is made to specification. Both apply established methods to produce goods, and neither is directly related to an experiment.

The evidence that supports it

  • The hypothesis for each prototype or insert, stating what the build was meant to test
  • Design files and revision history tying each build to a test
  • Test data and the evaluation that decided the next design
  • Purchase and build records separating prototype parts from production tooling
  • Fixed asset register entries for any tool or rig held as a depreciating asset, with its R&D use recorded
  • Records of what happened to each prototype after testing (scrapped, kept, sold or used)

Hardware R&D runs through physical things: prototypes, test rigs, fixtures, moulds. Each one raises two separate questions. Is making it an R&D activity at all? And if it is, how does its cost enter the claim? The answers often differ for items built in the same workshop in the same month.

Is the build part of the experiment?

What was builtUsual treatment
A prototype that is the variant being testedPart of the core activity, to the extent the test needs it
A test rig, fixture or jig built so experiments can runUsually supporting, if directly related to a core activity
A rig or fixture whose own design is the unknown being testedAssessed on the ordinary test; can be core
Further units, or finishing a prototype for sale or serviceProduces goods, so supporting only if it passes the dominant purpose test
A demonstration unit for investors, customers or a trade showTypically neither core nor supporting
Production tooling for a settled designNot R&D; applying known methods to make a product

The first row is the one most easily under-claimed. When the hypothesis concerns a geometry, a material or a mechanism, building that variant is the experiment, not preparation for it. The same applies to the third row: a fixture that has to hold a part in a way nobody has managed before is tested like any other variant. The demonstration row is the one most easily over-claimed. A unit polished for a pitch is commercial, whoever built it.

Tribunals look for a design that tests something. In Active Sports Management the Tribunal found no systematic progression and no new knowledge purpose in a customised basketball shoe: the work modified existing designs to suit a player, and no records showed hypotheses being formed and tested. The Federal Court dismissed the appeal in 2024. A record made before each build, saying what the build is meant to find out and what result would count as failure, is what separates a prototype from a product revision.

How the cost is claimed

Being an R&D activity does not mean every dollar is a deduction in the year it is spent. The ATO draws three lines that matter here. Which side of them an item falls on depends on the facts: whether it lasts beyond the test and is held for use, is used up, or is later sold or kept in service. The same mould insert can be consumed in one program and held as a tool in another.

  • Tools and rigs held as assets. Expenditure included in the cost of a tangible depreciating asset is not a notional R&D deduction. Its decline in value is claimed instead, to the extent the asset is used for R&D.
  • The people who build them. Section 355-225 excludes salary expenditure incurred on constructing depreciating assets, so building time is not claimed as R&D salary. It generally forms part of the asset's cost instead.
  • Prototypes consumed by testing. Materials and labour used up in a test, and not held as an asset, are generally expenditure on the activity in the usual way.

If a prototype is later sold or put to use, the feedstock rules can claw back the incentive on the inputs it consumed. Treatment of particular items is for the company's accountant or tax adviser to confirm. See notional deductions.

Neighbouring questions

Building larger equipment to test a process is covered on pilot plants, and running a process at production scale on manufacturing scale-up. Software prototypes follow the same principle with different traps, set out on MVPs and prototypes. The robotics page applies these rules to a whole sector.

Frequently asked questions

We sold the prototype after testing. Does that make it ineligible?
Not by itself. A genuine experiment stays core even if the prototype is later sold or used. The money changes: claim only the cost of building and testing it to the extent the experiment needed, and expect a feedstock adjustment where R&D inputs became a product that was sold or used.
Is a 3D printer or CNC machine bought for prototyping claimable?
Its purchase price is not a notional R&D deduction. As a depreciating asset, its decline in value over its effective life can be claimed to the extent it is used for R&D activities. A small business cannot also put the machine in a small business pool or write it off instantly, for any share of its use, so the company's accountant confirms the treatment.
Do software MVPs follow the same rules?
The principle is the same, the variant under test is the experiment, but software prototypes raise different questions about feature work and live products. They are covered on the MVPs and prototypes page.

Sources

  1. ATO, Expenditure you can't claim (R&D tax incentive)
  2. AusIndustry, Excluded R&D activities under the R&DTI
  3. AusIndustry, Manufacturing sector guide for R&DTI applicants

The R&D Tax Incentive is a self-assessment program. This page is general information, not tax, legal or financial advice; eligibility depends on your circumstances and you should seek independent advice for them.