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Core vs supporting activities: Australia

The two kinds of registered activity under Division 355: core R&D activities, defined as experiments with unknown outcomes, and supporting R&D activities, with the dominant purpose test that applies to some of them, and how to split a project into both.

AustraliaLast reviewed 1 October 2026

Australia is the only one of the seven countries whose law splits R&D into two kinds of activity and asks the claimant to register each separately. Core R&D activities are experimental activities whose outcome cannot be known in advance from current knowledge. They follow a systematic progression of work, from hypothesis to experiment, observation and evaluation, leading to logical conclusions, and are conducted to generate new knowledge. Supporting R&D activities are directly related to a core activity, and some must also be undertaken for the dominant purpose of supporting it. Getting the split right is most of the work of an Australian claim.

Proposed changes from 1 July 2028, not yet law. Proposed from 1 July 2028, announced in the 2026-27 Budget (12 May 2026) and not yet legislated: a 4.5 percentage point increase in offset rates for core R&D; removal of supporting R&D activities from eligibility; intensity threshold reduced from 2 percent to 1.5 percent; refundable offset turnover threshold raised to A$50 million; minimum notional deductions raised from A$20,000 to A$50,000; maximum expenditure threshold raised from A$150 million to A$200 million; companies more than 10 years old no longer eligible for the refundable offset. Current rules apply until then.

What it is

ElementCore R&D activitySupporting R&D activity
DefinitionAn experimental activity whose outcome cannot be known in advance, determined by a systematic progression of work based on established science, conducted to generate new knowledgeAn activity directly related to a core R&D activity
StatuteSection 355-25Section 355-30
Extra testMust not be an excluded activityDominant purpose test where the activity produces goods or services, is directly related to producing them, or is an excluded activity
Needs a hypothesisYesNo, but needs a named core activity it supports
Can be an excluded activityNoYes, if the dominant purpose test is met
ExamplesTrialling an alloy at different heat-treatment schedules to find whether a hardness target can be metMaking the test coupons; calibrating the test equipment; a literature review scoping the hypothesis

Who it applies to

Every registrant. There is no claim without at least one core activity: supporting activities exist only in relation to a core activity, and a registration of supporting activities alone is not eligible. A multi-year project can have core activities that start and stop in different years, and each year's registration lists the activities conducted in that year.

The dominant purpose test is where the split bites. It applies to a supporting activity that produces goods or services, or is directly related to producing them, or is one of the activities excluded from being core. Such an activity qualifies only if the dominant purpose for undertaking it was to support the core activity. A production run that doubles as a trial fails the test if its main purpose was to fill orders; a run made chiefly to test a hypothesis, with the output sold incidentally, passes, subject to the feedstock adjustment.

How it works

  1. Start from the technical unknowns, not the project. List the questions the team could not answer from existing knowledge. Each is a candidate core activity.
  2. Write the hypothesis and the experiment for each. If you cannot state what was proposed and how it was tested, it is not a core activity; it may be development.
  3. Attach the supporting activities. For each core activity, list the work done to enable or complete it: building rigs and prototypes, preparing samples, collecting data, calibration, literature reviews.
  4. Apply the dominant purpose test to any supporting activity that produces goods or services or is otherwise excluded, and record the reasoning.
  5. Set the boundaries. A core activity ends when the hypothesis is confirmed or rejected. Work after that point, such as scaling production or adding features, is not part of it.
  6. Register and keep records by activity, so that the department can examine each one on its own.

The department's Guide to Interpretation stresses that the systematic progression of work does not have to be elaborate, and that negative results are results: an experiment that disproves the hypothesis is a core activity. It also warns that describing a project in terms of its business goal, such as "develop a new app", does not describe a core activity.

Worked example

Illustrative example. Murray Composites Pty Ltd, a hypothetical company, wants to make a lighter irrigation pipe from a recycled plastic blend. The project as the business sees it has one goal. Registered as activities:

ActivityTypeWhy
Trialling blend ratios and extrusion temperatures to find whether burst pressure of 12 bar can be reached with at least 60% recycled contentCoreUnknown outcome, hypothesis tested by experiment
Testing UV additives to find whether field life of 10 years can be achieved with the recycled blendCoreSecond independent unknown
Modifying the extrusion die to run the trial blendsSupportingDirectly related; not production
Trial production runs of 2 km of pipe for burst and UV testingSupporting, dominant purpose testProduces goods; run chiefly to test, with offcuts sold as scrap, so passes
Grower survey on pipe diametersNot eligibleMarket research, excluded, and not supporting an experiment
Applying for the Australian Standard certification markNot eligibleCompliance with standards, excluded; not for the dominant purpose of supporting the experiments

Murray registers two core and two supporting activities. The pipe sold as scrap brings the feedstock adjustment into play on the trial runs.

Common questions

Can a whole project be one core activity? Only if the whole project is one experiment. Usually a project contains several core activities and a larger number of supporting ones.

Does the experiment have to be in a laboratory? No. Field trials, pilot plants and production-line tests are experiments if the outcome was unknown and the work was systematic.

What if we were confident it would work? If a competent professional could have known the outcome in advance, it is not a core activity, however much work it took.

Can an excluded activity ever be claimed? As a supporting activity, if its dominant purpose was to support a core activity. Never as a core activity.

Official sources

Educational content only, not tax advice. See the disclaimer.