Private ruling: Capital that is immediately deductible for environmental protection activities
Date of advice: 10 December 2015
Published: February 2016
Ruling period: All income years between xx 20xx and xx
Date scheme commenced: x July 20xx


Relevant facts and circumstances: The Trust incurred expenditure as part of a development project. Question 1 The ruling concerned whether expenditure incurred by a Trust was for the sole or dominant purpose of carrying on environmental protection activities, such that the Trust is entitled to deduct the expenditure under section 40-755 of the Income Tax Assessment Act 1997 (ITAA 1997)? Answer The Commissioner ruled that the expenditure was deductible under section 40-755 of the ITAA 1997. Question 2 The ruling concerned, if the answer to Question 1 is No, whether the expenditure incurred by the Trust were project amounts for the purposes of subsection 40-840(2) of the ITAA 1997? Answer Not necessary for the Commissioner to rule. Question 3 The ruling concern whether the project life for the purposes of section 40-845 of the ITAA 1997 was the period from when the development project become operational until the end of the development project? Answer Not necessary for the Commissioner to rule as question 2 did not establish any project amount/s.