bci christmas present, page-3

Recommendations by the panel policy transition group




11.1 $50 Million threshold offset


Recommendation 55: The $50 million threshold offset is intended to relieve a taxpayer of any
MRRT liability arising in respect of an income year when their MRRT profit is below $50 million.
The offset should have the following features:
the profit threshold should apply annually to a taxpayers MRRT profit (revenue less expenses);
the profit threshold should apply at an aggregate taxpayer level, defined by the small business
test in Subdivision 328-C of the Income Tax Assessment Act 1997;
the offset should be phased-down between $50 million and $100 million, such that the maximum
possible tax concession provided by the threshold ($11.25 million at $50 million), is reduced by
$0.225 for every $1 of MRRT profit above $50 million; and
the actual offset available to a taxpayer with an MRRT profit of between $50 million and
$100 million should be the lesser of:
o themaximumoffsetreducedbycreditableroyaltiespaidandthecreditequivalentofother
deductible amounts (carry-forward losses and starting base deductions); and
o MRRTotherwisepayable.