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Camalic Pty Ltd and Innovation and Science Australia (Taxation) [2020] AATA 1590

TAXATION – research and development tax incentive – whether the Applicant conducted a core R&D activity in the relevant financial years – whether development of an algorithm to predict shareholder value increases is a core R&D activity – whether claimed activities were undertaken in the year in which they were claimed – whether claimed activities were undertaken at all – whether development of algorithm is caught by exclusion in s. 355-25(1) Income Tax Assessment Act 1997 (Cth) – whether activities claimed as supporting R&D activities are core R&D activities – decision under review affirmed

PRACTICE AND PROCEDURE – procedural fairness – where claim by applicant that applications not assessed by people with sufficient knowledge of machine learning and software development – no evidence to support claim – no unfairness

Full decision here

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