Reforming the recognition of expenditure in Australian income tax law: A principled framework for the characterisation of capital outgoings and timing of deductions

The thesis examines the characterisation of expenditure and the corresponding timing of deductions in Australian income tax law. It uses the Schanz-Haig-Simons' income tax base as a starting point and analyses consistency with that base for seven selected topics: judicial characterisation of current and capital expenses, repairs, lease or public franchise agreements, live stock, tangible assets, intangible wasting assets and goodwill. Deviations arise from judicial doctrines that are not founded on a single principle, while statutory amendments have been inadequate to restore the measurement of net economic gains in Australian taxation. The thesis sets out a blueprint for reform.