Taxation Ruling
IT 2181
Income tax: depreciation: investment allowance - lift well
-
Please note that the PDF version is the authorised consolidated version of this ruling and amending notices.This document has been Withdrawn.View the Withdrawal notice for this document.
FOI status:
May be releasedFOI number: I 1199368FACTS
Advice was recently sought from this office whether a lift well constitutes plant eligible for depreciation and investment allowance deductions. It was suggested that a lift well was plant on the basis that a lift installation cannot operate without a specially constructed lift well.
2. The further question was raised whether, in a situation where a new building, including units of property in respect of which depreciation and investment allowance deductions are available, is constructed for one inclusive price, this office would accept an apportionment of costs made by the builder for the purpose of calculating depreciation and investment allowance deductions.
RULING
3. A lift well is not plant. It is part of the building structure, i.e. a part of the setting in which the activities for which a building is constructed are carried on.
4. An income tax deduction may be allowable under Division 10D which provides deduction in relation to capital expenditure on certain income producing non-residential buildings.
5. Where a building is constructed for a price which includes consideration for units of property in respect of which depreciation and investment allowance deductions are available, it is a matter for this office to determine the part of the price attributable to the units of property in respect of which depreciation and investment allowance deductions may be allowed. This office would be assisted in fixing the price of the various units by a genuine assessment by a builder of the part of the total price that represents the cost of each unit of eligible property.
COMMISSIONER OF TAXATION
30 July 1985
References
ATO references:
NO 84/4385-8
Date of effect:
Immediate
Date original memo issued:
27 June 1985
Related Rulings/Determinations:
IT 47
Subject References:
DEPRECIATION
INVESTMENT ALLOWANCE
ELIGIBILITY OF LIFT WELL
ASCERTAINMENT OF AMOUNT OF ELIGIBLE EXPENDITURE