Income tax: apportionment of expenses incurred by a superannuation entity only partly in gaining its assessable income

TR 2013/D7 discusses how a superannuation entity apportions a loss or outgoing that is only partly deductible under section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997) where it is only partly incurred in gaining or producing the entity's assessable income.

The Ruling also considers the potential effect of subsection 295-95(1) of the ITAA 1997 on such apportionment. Subsection 295-95(1) enables a superannuation fund to include all contributions in its assessable income for the purposes of claiming deductions for expenses related to obtaining contributions.

Taxation Ruling TR 93/17 Income tax: income tax deductions available to superannuation funds has been amended and now includes the key principles set out in TR 2013/D7.

Consequently, TR 2013/D7 has been replaced by the amended version of TR 93/17 which issued today.