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Taxation Determination

TD 94/65W

Income tax: property development: is a 'management reserve' taken into account in calculating notional taxable income under the estimated profits basis of returning income from a long term construction contract?

Attention TD 94/65 has been withdrawn as part of a project to review public rulings.
Attention This document has changed over time. View its history.

Notice of Withdrawal

Taxation Determination TD 94/65 is withdrawn with effect from today.

1. TD 94/65 explains that only actual costs that are identified as likely to be incurred during the contract period and which are properly deductible, are taken into account in calculating 'notional taxable income' under the estimated profits basis. General claims for 'management reserves' are not sufficiently informative to be taken into account.

2. TD 94/65 is being withdrawn to form part of a consolidated ruling on the tax treatment of long term construction contracts.

3. The issue covered by TD 94/65 is now covered in Taxation Ruling TR 2017/D8.

Commissioner of Taxation

18 October 2017

Previously issued as Draft TD 93/D255


ATO references:
NO  1-BD70DD7

ISSN 2205-6211

Related Rulings/Determinations:
TD 92/125
TD 92/131
TD 92/186
TD 94/39
IT 2450

Legislative references:
ITAA 51(1)

TD 94/65W history   Top  
   Date   Version   Change 
   21 July 1994   Original ruling   
 You are here ®  18 October 2017   Withdrawn   


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