General deductibility

Consideration should be given to the general deductibility of expenses within the corporate structure and whether any anti-avoidance provisions (such as the general anti-avoidance provisions of Part IVA) may apply to defeat the tax benefits sought by the taxpayer. Analysis should also consider whether certain expenditure is deductible in the year the expense is incurred, or alternatively deductible over a period. In a PPP arrangement, it is likely that finance-related expenses are incurred and such costs should be treated as deductible over the term of the loan or five years, whichever is less. Similarly, black-hole expenses should be treated as proportionately deductible over five years.