Taxation Determination TD 93/47







This Determination, to the extent that it is capable of being a 'public ruling' in terms of Part IVAAA of the Taxation Administration Act 1953 , is a public ruling for the purposes of that Part. Taxation Ruling TR 92/1 explains when a Determination is a public ruling and how it is binding on the Commissioner. Unless otherwise stated, this Determination applies to years commencing both before and after its date of issue. However, this Determination does not apply to taxpayers to the extent that it conflicts with the terms of a settlement of a dispute agreed to before the date of issue of the Determination (see paragraphs 21 and 22 of Taxation Ruling TR 92/20). | [ Note: This is a consolidated version of this document. Refer to the ATO Legal Database ( http://law.ato.gov.au ) to check its currency and to view the details of all changes.] | 1. We will accept valuations which are based on the cost of harvesting and processing the fruit. If it is difficult to precisely match specific expenses to the stock, we will accept a reasonable estimate. | 2. There are other expenses incurred prior to harvesting which should normally also be included in the valuation. These are recurring annual expenses, particularly those which relate to the fruit rather than to the tree or the soil. One example would be the cost of putting ripening bags on the bunches of bananas. | 3. However, we recognise that: | 4. For the above reasons we will accept valuations based only on harvesting and processing costs. | Example: Mr Cavendish is a banana grower. As at 30 June he had 200 cartons of bananas which had been picked and were not sold until July. His total production for the financial year was 5,000 cartons of bananas. His total picking and processing expenses for the year were $24,000. He calculates the value of stock as : 200 divided by 5,000 multiplied by 24,000. The value of stock on hand is $960. We will accept this method of valuation. | Commissioner of Taxation 25/3/93 | Previously issued as Draft TD 92/D203


Related rulings: TR 98/7
Legislative references: ITAA 1997 70-45
Subject references: trading stock banana growers