National Rental Affordability Scheme – taxation issues

What is the National Rental Affordability Scheme (NRAS)?

The National Rental Affordability Scheme (NRAS) encourages large-scale investment in affordable housing. It offers tax and cash incentives to providers of new dwellings, provided they are rented to low, and moderate, income households at 20% below market rates.

The NRAS is no longer taking new investments.

The NRAS started on 1 July 2008 and offers annual incentives for a period of 10 years. The NRAS incentive is tax-free income and has two components:

• an Australian Government contribution in the form of a refundable tax offset or payment to the value of $8,711.48 per dwelling per year in 2023–24. The Australian Government contribution is 75% of the total annual incentive
• a state or territory contribution in the form of direct financial support or an in-kind contribution to the value of at least $2,903.83 per dwelling per year in 2023–24. The state or territory contribution is 25% of the total annual incentive.

The incentive is indexed in line with the rental component of the consumer price index.

The Department of Social Services (DSS)External Link is responsible for administering and implementing the scheme.

To find out more about the NRAS, see About the National Rental Affordability Scheme (NRAS)External Link and National Rental Affordability Scheme RegulationsExternal Link.

NRAS refundable tax offsets

The Australian Government pays its contribution through refundable tax offsets. Eligible investors can claim it:

• in their annual tax return
• by lodging a short-form application if they are an income tax exempt entity who would not ordinarily lodge a tax return.

Tax endorsed charitable institutions are entitled to receive their incentive in the form of a grant from the Secretary of the DSS (the Housing Secretary), unless they elect to receive the incentive as a refundable tax offset.

What is a refundable tax offset?

Most tax offsets can only reduce the amount of tax you pay to zero – that is, if your tax offsets are greater than the amount of tax you are liable to pay, you do not get a refund of the excess amount. However, there are some exceptions to this general rule. These exceptions are classed as refundable tax offsets. The NRAS tax offset is a refundable tax offset. Refundable tax offsets can reduce the amount of tax you are liable to pay to an amount less than zero, which results in a refundable amount.

Eligibility for the NRAS tax offset

Your eligibility for the NRAS tax offset depends on whether you are:

• Individuals, corporate tax entities and super funds
• Members of an NRAS consortium
• Partnerships and trust beneficiaries who indirectly derive NRAS rent from a rental dwelling
• Trustee of a trust

Individuals, corporate tax entities and super funds

An individual, corporate tax entity or super fund is entitled to claim a refundable tax offset provided both of the following apply:

• They have been issued with a certificate from the Housing Secretary under the NRAS.
• The income year begins in the NRAS year to which the certificate relates.

Members of an NRAS consortium

Check your eligibility if you are a member of an NRAS consortium.

An individual, corporate tax entity or super fund that is a member of an NRAS consortium

Where an individual, a corporate tax entity or a super fund is a member of an NRAS consortium, they are entitled to claim a refundable tax offset provided both of the following apply:

• They have been issued with a certificate from the Housing Secretary under the NRAS.
• The income year begins in the NRAS year to which the certificate relates.

A partnership or trustee of a trust that is a member of an NRAS consortium

Where a partnership or a trustee of a trust is a member of an NRAS consortium, they are entitled to claim a refundable tax offset provided all of the following apply:

• They have been issued with a certificate from the Housing Secretary under the NRAS or the partnership or trustee of the trust is taken to have been issued with a certificate for its income year, which begins in the NRAS year.
• The rental dwellings covered by the certificate are those for which the partnership or trustee has derived NRAS rent.
• The amount in the certificate is the total of all the amounts worked out in relation to those rental dwellings.

The refundable tax offset will flow through to the partners or beneficiaries receiving the NRAS rent indirectly. Alternatively, if a trust has no net income, the trustee will be able to claim the refundable tax offset, where the member did not directly derive NRAS rent.

Approved participants seeking to relinquish their entitlement must elect to do so.

Partnerships and trust beneficiaries who indirectly derive NRAS rent from a rental dwelling

Circumstances may arise where the certificate is issued under the NRAS to an entity but the refundable tax offset is claimed by another entity – for example, when the certificate is issued to a trustee of a trust and the offset needs to be claimed by the beneficiaries. An entity is entitled to claim its share of the refundable tax offset consistent with its share of rental income from its participation in the NRAS through trusts and partnerships.

An entity that indirectly derives NRAS rent from a rental dwelling as a partner of a partnership, or as the trustee or a beneficiary of a trust, is entitled to claim the refundable tax offset provided both of the following apply:

• The trust or partnership that directly receives the rental income has been issued, or is taken to have been issued, a certificate from the Housing Secretary under the NRAS applicable to the dwelling.
• The income year of that trust or partnership begins in the NRAS year to which the certificate relates.

The entity indirectly receiving the NRAS rent may be:

• an individual
• a corporate entity (at the time the NRAS rent flows indirectly to it)
• the trustee of a trust that is liable to be assessed on a share of, or all or a part of, the trust's net income under section 98, 99 or 99A of the Income Tax Assessment Act 1936 (ITAA 1936) for that income year
• a super fund, an approved deposit fund or a pooled super trust.

A beneficiary of a trust cannot receive NRAS rent indirectly in any year that the trust has no net income. In this situation, the trustee may be able to claim the refundable tax offset.

NRAS rent will be taken to flow indirectly to either a beneficiary or the trustee of a trust but not to both.

NRAS rent flowing indirectly to an entity

NRAS rent is taken to flow indirectly in an income year to a partner in a partnership, a beneficiary of a trust or the trustee of a trust if all of the following apply:

• The NRAS rent is derived by the partnership or trustee of the trust, or flows indirectly to the partnership or to the trustee as a partner or beneficiary.
• One of the following conditions is satisfied
  • The partner has an individual interest in the partnership's net income for that year or is allowed a deduction for the partnership's loss for that year under paragraphs 92(1)(a) or (b) and 92(2)(a) or (b) of the ITAA 1936.
  • The beneficiary has a share of the trust's net income for that year to which paragraph 97(1)(a) of the ITAA 1936 applies, or an individual interest in the trust's net income for that year to which section 98A or 100 of the ITAA 1936 apply.
  • The trustee is liable to be assessed on a share of the trust's net income in respect of a beneficiary under section 98 of the ITAA 1936, or assessed on all or part of the trust's net income for that year under section 99 or 99A of the ITAA 1936.
  • The entity's share of the NRAS rent as calculated is a positive amount – that is, the entity must be entitled to part or all of the NRAS rent.

NRAS rent will be taken to flow indirectly to either a beneficiary or a trustee of a trust but not to both.

NRAS rent flowing indirectly through an entity

This occurs where there is an entity (intermediary entity) and the NRAS rent flows through that entity to another entity (the focal entity). These terms are used to work out an entity's share of the NRAS rent where it flows indirectly.

The entity's share of NRAS rent

An entity's share of NRAS rent is calculated under the table in subsection 380-30(3) of the Income Tax Assessment Act 1997 (ITAA 1997). This calculation is used to work out the entity's share of the NRAS rent where the NRAS rent flows indirectly to the entity. A focal entity's share of NRAS rent is calculated by referring to the share of the intermediary entity's share of the NRAS rent to which the intermediary entity is entitled. Column 2 in the table below provides the intermediary entity's share and column 3 provides the focal entity's share.

The table operates so that an entity's share of NRAS rent can be calculated where the distribution flows indirectly to either of the following:

• a partner in a partnership, or to a beneficiary or trustee of a trust, where the partnership or trustee derives the NRAS rent
• a partner in a partnership, or to a beneficiary or the trustee of a trust, where NRAS rent flows indirectly to the partnership or trustee through a chain of trusts or combination of trusts and partnerships.

An entity's share of NRAS rent is its share of the NRAS rent as the focal entity in column 3 of an item in the table.

In the case of a trust, the table operates so that if deductions exceed assessable income – that is, the trust has no net income – there can be no amount that flows indirectly to a beneficiary or through it to another entity.

Calculating an entity's share of NRAS rent

Item	Column 1: Identifying the intermediary and focal entities	Column 2: The intermediary entity's share of the NRAS rent is	Column 3: The focal entity's share of the NRAS rent is
1	A partnership is the intermediary entity and a partner in that partnership is the focal entity if both of the following apply: NRAS rent is derived by the partnership. The partner has, in respect of the partnership, an individual interest in the partnership's net income or loss for that income year that is covered by subsections 92(1) and (2) of the ITAA 1936 (about income and deductions of partners).	the NRAS rent.	the amount of the NRAS rent that is taken into account in working out the amount of that individual's interest.
2	A partnership is the intermediary entity and a partner in that partnership is the focal entity if both of the following apply: NRAS rent flows indirectly to the partnership as a beneficiary of a trust. The partner has, in respect of the partnership, an individual interest in the partnership's net income or loss for that income year that is covered by subsections 92(1) and (2) of the ITAA 1936 (about income and deductions of partners).	the amount worked out under column 3 of item 3 or 4 of this table where the partnership, as a beneficiary, is the focal entity in that item.	the amount worked out under column 2 of this item that is attributable to the partner, having regard to the partnership agreement and any other relevant circumstances.
3	The trustee of a trust is the intermediary entity and the trustee or a beneficiary of the trust is the focal entity if both of the following apply: NRAS rent is derived by the trustee. The trustee or beneficiary has, in respect of the trust, a share amount. A beneficiary has a share amount for an income year if they have either of the following: a share of the trust's net income for that income year that they are presently entitled to and not under a legal disability an individual interest in the trust's net income for the income year that is covered by section 98A or 100 of the ITAA 1936. This is the case regardless of whether or not that share amount becomes assessable income in the hands of the beneficiary. A trustee has a share amount for an income year if they are liable or would be liable to be assessed in respect of an amount that is either of the following: a share of the trust's net income for that income year under section 98 of the ITAA 1936 all or a part of the trust's net income for that income year under section 99 or 99A of the ITAA 1936. This is the case regardless of whether or not the share amount becomes assessable income in the hands of the trustee.	if the trust has a positive amount of net income for that year – the NRAS rent otherwise – nil.	the amount worked out under column 2 of this item as is taken into account in working out that share amount.
4	The trustee of a trust is the intermediary entity and the trustee or a beneficiary of the trust is the focal entity if both of the following apply: NRAS rent flows indirectly to the trustee as a partner in a partnership or as a beneficiary of another trust. The trustee or beneficiary has, in respect of the trust, a share amount. A beneficiary has a share amount for an income year if they have either of the following: a share of the trust's net income for that income year that they are presently entitled to and not under a legal disability an individual interest in the trust's net income for that income year that is covered by section 98A or 100 of the ITAA 1936. This is the case regardless of whether or not that share amount becomes assessable income in the hands of the beneficiary. A trustee has a share amount for an income year if they are liable or would be liable to be assessed in respect of an amount that is either of the following: a share of the trust's net income for that income year under section 98 of the ITAA 1936 all or a part of the trust's net income for that income year under section 99 or 99A of the ITAA 1936. This is the case regardless of whether or not the share amount becomes assessable income in the hands of the trustee.	the amount worked out under column 3 of either of the following: item 1 or 2 of this table where the trustee, as a partner, is the focal entity in that item item 3 or a previous application of this item where the trustee, as a beneficiary is the focal entity in that item.	the amount worked out under column 2 of this item that is attributable to the focal entity in this item, having regard to the trust deed and any other relevant circumstances.

In item 3 or 4 of the table, the trustee of a trust can be both the intermediary entity and the focal entity in the same item.

Trustee of a trust

A trustee of a trust (rather than the trust's beneficiaries) is entitled to a refundable tax offset if the Housing Secretary has issued the trustee a certificate under the NRAS and the trust has no net income. Similarly, a trustee of a trust is entitled to a refundable tax offset if both of the following apply:

• The trust to which the offset flows has no net income.
• The NRAS refundable tax offset flows to this trust from another entity because the trust is either
  • a member of an NRAS consortium
  • a partner of a partnership
  • a beneficiary of another trust that has net income.

Trustees assessable on net income of the trust are also entitled to a share of the offset.

The trustee of a trust that is indirectly entitled to NRAS rent can generally only claim the offset in years the trust has net income.

If the trustee of a trust is entitled to a refundable tax offset, neither a beneficiary of this trust nor a subsequent entity to which the NRAS rent flows indirectly is entitled to the refundable tax offset.

Claiming the NRAS refundable tax offset

How you claim the NRAS refundable tax offset depends on if you are:

• Individuals
• Corporate tax entities
• Super funds
• Partnerships and partners
• Trusts, trustees and beneficiaries
• Income tax exempt entities
• Members of an NRAS consortium

Individuals

Eligible individuals can claim the NRAS refundable tax offset at the partnership and trust income question in their tax return (supplementary section) or through myTax.

While the tax return label is specific to partnerships and trusts, all individuals making a claim must use this label. This includes individuals who are claiming because they are a member of an NRAS consortium. Do not claim the refundable tax offset under any other tax offset labels.

Corporate tax entities

Eligible corporate tax entities can claim the NRAS refundable tax offset, or a share of it, in the Company tax return information statement (National Rental Affordability Scheme).

The amount recorded in the information statement at item 12 – label J, must also be included in the calculation statement at label E.

Super funds

Eligible super funds can claim the NRAS refundable tax offset, or a share of it, in the income tax calculation statement (refundable tax offsets) in the Fund income tax return.

An eligible self-managed super fund can claim the NRAS refundable tax offset, or a share of it, in the income tax calculation statement (refundable tax offsets) in the Self-managed superannuation fund annual return.

Partnerships and partners

A partnership that has received or is taken to have received an NRAS refundable tax offset certificate can claim the total NRAS refundable tax offset in the business and professional items section of the Partnership tax return.

Each partner's share of the NRAS refundable tax offset will be included as part of the statement of distribution in the return.

The partners of a partnership who are entitled to the NRAS refundable tax offset must claim their share in their respective tax returns.

The following steps show how to calculate your NRAS tax offset for each dwelling if you are a partner of a partnership who indirectly derives NRAS rent from a rental dwelling.

1. The certificate the partnership received states the amount of the refundable tax offset for that entity.
2. Apportion that amount by the NRAS rent you derive from the dwelling for the income year and the total NRAS rent derived from rental dwellings covered by the certificate for the income year.
3. Add together the amounts you have worked out for each dwelling to work out the total amount of your refundable tax offset. This is the amount of the tax offset you can claim in your tax return.

Trusts, trustees and beneficiaries

A trust that has received or is taken to have received an NRAS refundable tax offset certificate can claim the total NRAS refundable tax offset amount in the Trust tax return.

Each beneficiary's share of the NRAS refundable tax offset will be included in the statement of distribution in the return.

The beneficiaries of a trust who are entitled to the NRAS refundable tax offset must claim their share in their respective tax returns.

If the trust has no net income, the full amount of the NRAS refundable tax offset will be included under the column entitled 'Income to which no beneficiary is presently entitled and in which no indefeasible vested interest, and the trustee's share of credit for tax deducted' in the statement of distribution in the Trust tax return.

The following steps show how to calculate your NRAS tax offset for each dwelling if you are a trust beneficiary who indirectly derives NRAS rent from a rental dwelling.

1. The certificate the trust received states the amount of the refundable tax offset for that entity.
2. Apportion that amount by the NRAS rent you derive from the dwelling for the income year and the total NRAS rent derived from rental dwellings covered by the certificate for the income year.
3. Add together the amounts you have worked out for each dwelling to work out the total amount of your refundable tax offset. This is the amount of the tax offset you can claim in your tax return.

Income tax exempt entities

Endorsed charitable institutions participating in the NRAS in their own right can receive their NRAS incentive as a payment from the Housing Secretary. Where an NRAS participant was an endorsed charitable institution for only part of an NRAS year, special apportionment rules apply.

An income tax exempt entity that is entitled to the NRAS refundable tax offset can elect to claim it by completing the Application for refund of tax offset – National Rental Affordability Scheme – Income tax exempt entities.

Members of an NRAS consortium

Members of an NRAS consortium who are entitled to the NRAS refundable tax offset must claim their share in their respective tax returns.

The following steps show how the NRAS tax offset is calculated per dwelling for a member of an NRAS consortium.

1. The certificate the approved participant of the NRAS consortium receives from the Housing Secretary states the amount of NRAS tax offset for each rental dwelling. The approved participant should identify your share of the NRAS tax offset.
2. Divide the amount of NRAS rent you derived from the dwelling for the income year by the total NRAS rent derived from that rental dwelling for the income year. If you were the only one deriving rent from this dwelling, the answer to step 2 will be equal to 1.
3. Multiply the amount at step 1 by the amount you worked out at step 2. The result is the amount of NRAS tax offset you are entitled to for that rental dwelling.
4. If you have derived NRAS rent for more than one rental dwelling, repeat steps 1–3 for each rental dwelling.
5. Add together the amounts you worked out at step 3 for each rental dwelling you derived NRAS rent from. This is the amount of NRAS tax offset you are entitled to.
6. Claim the amount at step 5 in your tax return.

It is recommended that the approved participant of the NRAS consortium provide a signed and dated letter addressed to the member of the consortium that contains the information necessary for the member to make their claim. That information could be presented as follows:

Amendments to NRAS tax offset entitlements

The Housing Secretary may issue an amended certificate. If this occurs, the amount of the tax offset is worked out using the amount stated in the amended certificate. This means you will need to apply to us for an amended assessment, subject to the statutory time limits applicable to requesting an amendment.

State and territory contributions

The state and territory contributions you receive (whether directly or indirectly, such as through an NRAS consortium of which you are a member) in cash or in-kind financial support (such as reduced stamp duty or land tax) for participating in the NRAS are non-assessable and non-exempt (NANE) for tax purposes. This means they are not included in your assessable income.

Capital gains tax and NRAS

There are no capital gains tax consequences from providing incentives or other benefits under the NRAS.

Effect of NRAS on charitable status

Existing charities could participate in the establishment phase of NRAS (2008–09 and 2009–10 income years) without affecting their charitable status, due to the transitional provisions.

In the 2010–11 and later years, the charitable status of a charity may be affected by participating in the NRAS, as normal definitions of a charitable purpose apply.

Election to relinquish your entitlement to the NRAS tax offset

This election allows approved participants of NRAS consortiums to relinquish their entitlement to the NRAS tax offset for an NRAS year in favour of certain other members of their consortium where the member did not directly derive NRAS rent. For an example of when this can occur, refer to ATO ID 2009/146.

Who can make this election?

You are eligible to make this election if the following apply:

• You are the approved participant (within the meaning of the regulations made for the purposes of the National Rental Affordability Scheme Act 2008External Link) of a National Rental Affordability Scheme (NRAS) consortium (or you were the approved participant at any time during the NRAS year).
• You were issued a certificate which entitles you to the NRAS tax offset.
• You want to make an election to relinquish your entitlement to the NRAS tax offset to a member of the consortium.

What should you do with this election?

You must give a copy of the election to the member of the NRAS consortium who will be entitled to an NRAS tax offset as a result of the election. You must keep a copy of the completed election and make it available if we request it. Do not send your completed election to us.

When should you make this election?

The election must be made within 30 days after the day the Housing Secretary issues an NRAS certificate to the NRAS approved participant in relation to each NRAS year.

If the Housing Secretary issues an amended NRAS certificate for the NRAS dwelling for the income year to the NRAS approved participant, the election must be made 30 days after this day.

How much of the entitlement can you relinquish?

You can only pass on an amount of your NRAS tax offset entitlement equal to the proportion of the total NRAS rent derived from an NRAS dwelling for the income year belonging to the member. That amount would be equal to the member's rent proportion of the total rent.

Can you change the election after it is made?

Once an election is made it cannot be revoked.

What is an approved form?

The legislation says you have to make this election in an 'approved form'. What will be considered an approved form for the purposes of making this election?

There is no specific approved form that we have published for the purposes of making this election. However, an election will be considered to be made in the 'approved form' as long as the election records contain the following details:

• a statement that the document is the election of the approved participant to relinquish their entitlement to the NRAS tax offset under Division 380 of the ITAA 1997
• name of the approved applicant who is making the election (the electing member)
• name of the members to whom the NRAS entitlement is being transferred
• mailing address for the member
• NRAS certificate ID
• NRAS dwelling ID
• NRAS dwelling address
• amount of entitlement
• relevant NRAS year
• date election was made
• it is dated and signed by the approved participant.

This can be satisfied by providing a signed and dated letter addressed to the member which contains the following:

NRAS rental income and deductions

If you are an investor in an NRAS property, you must declare the income you receive and will be able to claim a deduction for the same type of expenses you have incurred as an investor who has invested in a non-NRAS property.

However, any amount that you can claim as a deduction must be apportioned to the extent that these expenses relate to the earning of non-assessable and non-exempt (NANE) income. Deductions for the decline in value of any depreciating assets, as well as the cost of capital works, are also subject to apportionment.

General deductions

Generally, a deduction can be claimed for rental property expenses that are incurred in gaining or producing assessable income. The expense must not be a private, domestic or capital expense or incurred in relation to gaining or producing exempt income or NANE income.

While a taxpayer who invests in an NRAS property receives assessable rental income they also receive government incentives, including state government NANE income. In order to receive government incentives, including state government NANE income, investors must rent out their property at 20% less than the market rent.

If expenditure related to the NRAS rental properties had been incurred solely for the purpose of gaining assessable income, it would be wholly deductible. However, as investors in an NRAS property incur expenses in order to both earn assessable income and NANE income, any expenses an investor incurs in order to invest in NRAS must be apportioned.

Borrowing expenses

You can deduct expenditure you incur (such as loan fees) in order to borrow money, to the extent that you use the money for the purpose of producing assessable income. The deduction is spread over the lesser of 5 years or the length of the loan.

Where the borrowed money is used partly for a non-assessable income producing purpose it is necessary to apportion any deduction claimed for borrowing expenses. This includes expenses incurred in order to borrow money to purchase a NRAS property as the borrowed money is used to earn NANE income as well as assessable income. The allowable deduction for borrowing expenses must therefore be apportioned.

Capital allowances

A depreciating asset is an asset that has a limited effective life and can reasonably be expected to decline in value over the time it is used, with certain exceptions.

You can deduct an amount equal to the decline in value for an income year of a depreciating asset that you held for any time during the year. You must reduce the deduction by any part of the asset's decline in value that is attributable to your use of the asset, or you having it installed ready for use, for a purpose other than a taxable purpose. 'Taxable purpose' includes 'the purpose of producing assessable income'.

Depreciating assets held by an NRAS investor are in part used to produce NANE income. As these assets have been used for a purpose other than a taxable purpose (that is, to earn NANE income) any deduction claimed in respect to the decline in value of these assets must be apportioned.

Deductions for capital works

To deduct an amount for capital works an investor’s construction expenditure must be used for the purpose of producing assessable income or conducting research and development (R&D) activities.

Taxation Ruling TR 97/25 notes that where capital works expenditure is wholly attributable to a construction expenditure area that is used partly in a deductible way then apportionment of the allowable deduction for capital works will be necessary. Therefore, the deduction for capital works must be reduced to the extent the investment in the NRAS properties produces NANE income.

Examples to help you in reporting

The contract you have with the approved participant and related parties regarding your NRAS property affect how you complete your tax return.

These are examples only and you will need the details from your approved participant to know the exact amounts each year.

Two basic contracts exist:

• Arrangement A – you (the property owner) have leased your property to the approved participant or a related party for a commercial rent.
• Arrangement B – the approved participant or related party are merely acting as agents for you as a property manager.

Arrangement A

In Arrangement A:

• you lease your property to an NRAS approved participant
• you do not claim the tax offset
• the amounts you receive under the lease are assessable. The amounts may be described as rent, NRAS rent, NRAS tax offset, State incentive, National Rental Incentive (NRI) etc
• you apportion expenses according to your equitable interest (the share you own in the property – this may be 50-50 with someone).

Arrangement B

In Arrangement B:

• you use an NRAS approved participant as a property manager
• you can claim the NRAS tax offset according to your equitable interest
• the rent you receive from the property manager is assessable income
• you are entitled to claim the NRAS tax offset as advised by the approved participant for the NRAS year, however this does not need to be included in your assessable income
• the NRI or state government incentive is non-assessable non-exempt (NANE) income – NANE is an amount which is excluded from your assessable income and ignored for the purposes of calculating your available losses
• you apportion your deductions using the following formula.

Deduction × (Assessable rent ÷ (Assessable rent + NANE income)) = NRAS deduction.

For more information, see TR 97/25 Income tax: property development: deduction for capital expenditure on construction of income producing capital works, including buildings and structural improvements.

Certainty about the tax implications of your arrangement

If you would like to know whether you are entitled to an NRAS tax offset from your involvement in a non-entity joint venture, you can ask us for a private ruling or class ruling.

Definitions

The following terms have been defined below:

• Corporate tax entity
• Derived
• Income tax exempt entities
• Non-entity joint venture
• NRAS consortium
• NRAS rent
• NRAS year
• Super fund

Corporate tax entity

An entity is a corporate tax entity if the entity is a company, a corporate limited partnership, a corporate unit trust or a public trading trust in relation to the income year. Corporate tax entities can include non-profit entities that are taxable or income tax exempt.

Derived

In working out whether you have derived an amount of ordinary income and, if so, when you derived it, you are taken to have received the amount as soon as it is applied or dealt with in any way on your behalf or as you direct.

Income tax exempt entities

This is an entity that is exempt from income tax. For example, an endorsed charitable institution or a non-profit entity that self-assesses is income tax exempt.

Non-entity joint venture

This is an arrangement that we are satisfied is both of the following:

• a contractual arrangement under which 2 or more parties undertake an economic activity that is subject to the joint control of the parties
• entered into to obtain individual benefits for the parties in the form of a share of the output of the arrangement rather than joint or collective profits for all the parties.

NRAS consortium

This is the mechanism by which a group of taxpayers collectively participating in NRAS each become entitled to an NRAS tax offset. An NRAS consortium is a consortium, joint venture or non-entity joint venture established by a contractual arrangement that facilitates the leasing of approved rental dwellings under NRAS.

NRAS rent

This is the rent derived in respect of a rental dwelling from renting it on an affordable housing basis under the NRAS for an income year.

NRAS year

The period 1 May to 30 April each year.

Super fund

This is a fund that is an indefinitely continuing fund and is a provident, benefit, superannuation or retirement fund or a public sector superannuation scheme.