AAT finds taxpayers not carrying on a business of providing services to their company
Taxpayers not entitled to various deductions for agistment and animal husbandry services provided to their own company, AAT rules
The Administrative Appeals Tribunal (‘AAT’) has held that two taxpayers were not carrying on a business of providing services to a company (which they owned) and consequently were not entitled to various deductions.
The taxpayers had claimed those deductions on the basis that they were carrying on a business of providing agistment and full care animal husbandry and veterinary services to their company.
The AAT concluded that, on balance, the agistment arrangements did not constitute a ‘business’.
The AAT noted in this regard that there was a degree of systematic, business-like behaviour. However, the AAT was of the view that the absence of a profit-making purpose, the uncommercial nature of the transactions and similar considerations nevertheless led to the conclusion that a business was not being carried on.