Glossary

Feedstock adjustment: when R&D outputs that are sold or used claw back part of the offset

A feedstock adjustment applies when goods or materials claimed as R&D inputs become tangible products the company sells or applies to its own use. The clawback amount is the lesser of the feedstock revenue and the claimed input and energy spend (s 355-445); only its incentive component, grossed up, is added to assessable income.

Reviewed by George WalchFacts last verified

Example

An illustrative company taxed at 25% claims $80,000 of polymer resin and directly consumed energy in experimental moulding runs, all at the 43.5% refundable rate. Batches that meet specification are sold for $50,000. The clawback amount is the lesser figure, $50,000. Its incentive part is $50,000 x 18.5% = $9,250, which the formula grosses up to $37,000 of extra assessable income.

Legislative reference: Income Tax Assessment Act 1997, s 355-445 (feedstock adjustments) and s 355-450 (amount included in assessable income); ATO ruling TR 2013/3

Related terms: clawback, notional deductions, R&D schedule, decline in value, connected and affiliated entities

Feedstock is the material an experiment consumes and turns into something tangible. The R&D Tax Incentive pays an offset on that material, so when the output is sold or put to use, section 355-445 makes the company give back the incentive part. It is one of the three clawback triggers.

What triggers it

All of these must be true:

  • the company claimed notional deductions for feedstock inputs (goods or materials), for energy input directly into transforming them, or for the decline in value of assets used to acquire or produce those inputs;
  • the R&D produced one or more tangible products (feedstock outputs); and
  • in the current year an output, or a product made from it, is supplied to another entity or applied to the company's own use, other than to transform it further for supply.

Supply or use by a connected entity or affiliate counts too.

How the amount is worked out

The clawback amount is the lesser of feedstock revenue and the feedstock expenditure reasonably attributable to that output. Where the output is processed further before sale, the ATO apportions the sale value by cost of the feedstock output over cost of the finished product. Section 355-450 then includes only the incentive component in assessable income, grossed up at the current tax rate.

Three rules prevent double counting: an output feeding a later R&D activity is adjusted only at the end of the chain; recurring own use triggers once; and a later sale of an output already adjusted for own use triggers nothing.

Where it shows up

Feedstock is common in manufacturing scale-up, pilot plants and agtech field trials. The amount is reported in Part B of the R&D schedule, which the company's accountant prepares. Older references, including TA 2017/5, point to section 355-465; feedstock now sits in section 355-445.

Frequently asked questions

Does a feedstock adjustment reduce the offset already received?
No. The offset stands. The adjustment works by increasing assessable income in the year the output is sold or used, which recovers the incentive part of the offset through tax.
Are failed batches that are scrapped caught?
Not if they are never supplied or used. The trigger is supplying the output, or a product made from it, to someone else or applying it to the company's own use.
Does software count as feedstock?
The rules apply to goods or materials transformed into tangible products, so pure software work does not usually involve feedstock. Hardware prototypes and pilot production runs can.

Sources

  1. Income Tax Assessment Act 1997, ss 355-445 and 355-450 (Federal Register of Legislation)
  2. ATO, Clawback of feedstock adjustments

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.