期刊名称：Journal of the Australasian Tax Teachers Association
印刷版ISSN：1832-911X
电子版ISSN：1832-911X
出版年度：2008
卷号：3
期号：2
出版社：Australasian Tax Teachers Association
摘要：When the theme for the 2008 Australasian Tax Teachers' Conference was announced (The Devil's in the Detail), the author immediately thought of the non-commercial losses provisions. These provisions are contained in Division 35 of the Income Tax Assessment Act 1997 (Cth) ('ITAA 1997') and restrict individuals from offsetting losses from non-commercial activities against other income. Division 35 was introduced following the Review of Business Taxation Report, A Tax System Redesigned ('Ralph Report').1The Ralph Report stated that the primary rationale for this reform was to improve the integrity of the taxation system by restricting loss deductions for hobby style taxpayers.2The Report asserted: Many of these activities are no more than hobb ies and/or lifestyle choices but even those that have business like characteristics (according to existing law) are often unlikely to ever make a profit and do not have a significant commercial purpose or character. They continue in a net loss position year after year, offsetting so-called business losses against other income, notably salary and wages. On average they make little or no contribution to the revenue-raising task but gain a significant tax advantage.3
