In a media release issued on 22 December 2009, the Commissioner, Michael D’Ascenzo, announced the release of Taxpayer Alert TA 2009/21 entitled "R&D tax offset abuse through registered research agencies". These arrangements involve a company structuring contracts with a registered research agency to provide research and development (R&D) services in order to access the R&D tax offset. The agreement involves what appears to be a prepayment for services up to 13 months in advance, but the ATO is concerned the expenditure may not meet the requirements to be tax deductible.
For a copy of the ATO media release, No 2009/68, 22 December 2009, go here
For a copy of TA 2009/21, go here