For educational purposes only. Not tax, legal, or financial advice. Tax laws change frequently. Consult a registered tax agent or CPA for your specific situation.

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    TaxKiln Australia
    Audit + compliance

    Non-Commercial Loss Rules — When You Can (and Can't) Offset Business Losses Against Other Income

    If your business runs at a loss and you also have salary or investment income, the non-commercial loss rules (Division 35 ITAA 1997) decide whether you can offset the business loss against other income — or whether the loss is quarantined until the business turns profitable.

    The four tests

    • Assessable income test (s 35-30) — the activity generated at least $20,000 of assessable income in the year.
    • Profits test (s 35-35) — the activity produced a tax profit in at least 3 of the past 5 income years (including the current year).
    • Real property test (s 35-40) — real property of at least $500,000 is used in the activity on a continuing basis.
    • Other assets test (s 35-45) — other assets (plant, vehicles, livestock — excluding cars) of at least $100,000 are used on a continuing basis.

    Common mistakes

    • Assuming any "business" loss offsets salary income. Quarantining is the default for new or sub-scale activities under $250,000.
    • Misclassifying hobby income as business. Hobby income isn't assessable — but it also isn't deductible. Get this wrong both ways and you lose either side.
    • Forgetting the high-income lockout. Over $250,000 of combined income, no test is enough — the loss is quarantined regardless of scale (subject to s 35-55 discretion).
    • Not asking for s 35-55 discretion. Lead-time activities (vineyards, software with R&D burn) often qualify but you have to apply for the private ruling.

    Cross-references

    See also Income Tax Calculator for the PAYG salary side of the equation, and the Entity Extraction Calculator if you're considering whether a different structure would change the loss treatment.

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