This Ruling examines schemes connected with intellectual property. Specifically, it examines tax benefit transfer arrangements under which taxpayers, with limited or no financial exposure to the success or failure of the commercialisation of the intellectual property, enter into contrived arrangements to obtain the benefit of deductions from developers of intellectual property who cannot benefit directly under Division 40 of Part 2-10 of the Income Tax Assessment Act 1997 ('ITAA 1997'). These arrangements distort the tax concession intended by Division 40 and are considered to be tax avoidance schemes.
maintenance