Glossary

Decline in value: how equipment used for R&D earns the offset

Decline in value is how R&D equipment enters the R&D Tax Incentive. Instead of the purchase price, a company claims each tangible depreciating asset's Division 40 decline in value for the period and extent it was used for registered R&D. It is a notional deduction under section 355-305 ITAA 1997, spread over the asset's effective life.

Reviewed by George WalchFacts last verified

Example

An illustrative company buys a $36,000 GPU workstation on 1 July 2025 and, for this example, uses a 4-year effective life on the prime cost method, so its decline in value is $9,000 a year. Run logs show 70% of its use was for registered experiments. Its notional deduction is $6,300, worth $2,740.50 at the 43.5% refundable rate.

Legislative reference: Income Tax Assessment Act 1997, ss 355-305 and 355-310 (notional decline in value), s 355-315 (balancing adjustments) and s 355-225(1)(b) (asset cost excluded)

Related terms: notional deductions, clawback, feedstock, cooperative research centre

Section 355-225(1)(b) keeps the cost of a tangible depreciating asset out of ordinary R&D expenditure. The asset still counts, but through Subdivision 355-E: the company notionally deducts its decline in value, worked out under Division 40, for the time and extent it was used for R&D.

The conditions

Under section 355-305(1) the company must:

  • be registered for the income year for R&D activities that meet the section 355-210 conditions;
  • hold the asset and use it in the year to conduct those activities;
  • be able to deduct an amount under section 40-25 if Division 40 applied as modified by section 355-310; and
  • not have deducted an amount for the asset in an earlier year under the small business pool rules or through a low-value pool.

Working out the extent of R&D use

The law asks for the extent of use for R&D, not a set method. A reasonable approach follows how each asset is actually used:

  • an asset issued to one person takes that person's R&D share of time;
  • a shared asset, such as a GPU server or lab instrument, takes the R&D share of its use: measured use from scheduler, booking or run logs where the company has it, otherwise its users' R&D share, with a note of why that is a fair proxy;
  • an asset bought only for registered experiments, such as a test rig, can have its whole decline in value claimed, with a record that it was used for nothing else.

What is excluded, and what happens on disposal

Buildings and capital works are excluded, and only tangible assets qualify. An asset paid for out of CRC contributions or Commonwealth CRC funding cannot be claimed (see Cooperative Research Centre). When an asset is sold or scrapped, a balancing adjustment applies, and a further clawback or catch-up deduction adjusts the incentive part. Assets matter most for prototypes and tooling and pilot plants, while cloud compute costs are expenses instead.

Frequently asked questions

Can a company claim the full cost of R&D equipment in the year it is bought?
Not through the R&D offset. The cost is excluded from ordinary R&D expenditure, and the asset earns the offset through its decline in value, spread over its effective life.
What about a laptop written off under small business rules?
Pooling or writing an asset off under the small business or low-value pool rules can end its R&D claim. Ask the company's accountant before choosing the treatment for any asset used for R&D.
Is cloud compute decline in value?
No. Cloud services are an expense, not an asset the company holds, so they are apportioned as R&D expenditure rather than depreciated.

Sources

  1. Income Tax Assessment Act 1997, Subdivision 355-E (Federal Register of Legislation)
  2. ATO, Expenditure you can claim (decline in value of assets)
  3. ATO, Balancing adjustments for R&D assets

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.