Understanding Aggregated Turnover for the R&D Tax Incentive
Getting your R&D tax incentive claim wrong because of aggregated turnover miscalculations could cost your business millions. Here’s everything you need to know about understanding aggregated turnover for the R&D tax incentive – from the critical $20 million threshold that determines refundable vs non-refundable offsets, to identifying connected entities and avoiding costly mistakes that have bankrupted Australian companies.
Quick Summary: Understanding aggregated turnover for the R&D tax incentive is crucial for Australian companies claiming R&D benefits. Companies with aggregated turnover under $20 million qualify for refundable offsets (43.5% rate), while those above receive non-refundable offsets with intensity-based premiums. The calculation includes your company plus all connected and affiliated entities’ revenue, making proper identification and calculation essential for maximising your claim value.
What Exactly Is Aggregated Turnover and Why Should You Care? 💰
Think aggregated turnover is just your company’s revenue?
Think again.
This simple misunderstanding has cost Australian businesses millions in lost R&D benefits. Understanding aggregated turnover for the R&D tax incentive means grasping that it’s not just about your primary business income – it’s about the total revenue picture across your entire business network.
According to the Income Tax Assessment Act 1997, aggregated turnover includes your annual turnover plus any connected or affiliated entities’ turnover. This broader view catches many business owners off guard.
Here’s the kicker: one wrong calculation can shift you from receiving cash back to just getting tax deductions.
The Million-Dollar Threshold That Changes Everything
The $20 million aggregated turnover threshold isn’t just a number – it’s the line between getting cash in your bank account or waiting for future tax savings.
Under $20 Million:
- Refundable 43.5% tax offset
- Get cash back even if you’re in a loss position
- Perfect for growing businesses needing immediate cash flow
$20 Million or More:
- Non-refundable offset with intensity-based rates
- Company tax rate plus 8.5% (up to 2% R&D intensity)
- Company tax rate plus 16.5% (above 2% R&D intensity)
Why does this matter so much?
Cash flow.
Startups and growing businesses often operate at a loss while developing innovative products. The refundable offset provides immediate cash injection when you need it most.

How Aggregated Turnover Actually Works
Let’s break down what counts as aggregated turnover because the details matter here.
Your Entity’s Annual Turnover
Annual turnover means the total ordinary income your entity derives during the income year from ordinary business activities. This includes:
- Worldwide income (yes, foreign revenue counts)
- All ordinary business income
- Excludes GST
- Proportional calculation if you haven’t operated the full year
Key Point: If your R&D entity doesn’t conduct business for the entire income year, the annual turnover gets calculated proportionally based on a reasonable full-year estimate.
Connected Entities – The 40% Control Test
Connected entities are those where your R&D entity controls at least 40% of the voting power or has the right to receive at least 40% of any dividends or capital distributions.
This 40% threshold catches many businesses by surprise.
You might think you’re independent, but if you own 41% of another company, their entire turnover gets added to yours.
Affiliated Entities – The Trickier Calculation
Affiliates are entities that act in accordance with your directions or wishes, or vice versa. This relationship doesn’t require ownership – it’s about influence and control.
Common affiliate scenarios:
- Family trusts controlled by the same people
- Companies sharing common directors with decision-making power
- Entities following business directions from the same source
The Step-by-Step Calculation Process 📊
Ready to calculate your aggregated turnover? Here’s how to do it properly.
Step 1: Identify Your R&D Entity’s Annual Turnover
Start with your primary entity’s revenue for the income year. Include all ordinary business income but exclude:
- GST
- Capital gains (in most cases)
- One-off government grants (sometimes)
Step 2: Map All Connected Entities
List every entity where you have:
- 40% or more voting control
- Rights to 40% or more of distributions
- Practical control through agreements
Step 3: Identify Affiliated Entities
Look for entities that:
- Follow your business directions
- Share common control with your R&D entity
- Act in accordance with your wishes
Step 4: Calculate Each Entity’s Relevant Turnover
For each connected or affiliated entity, calculate their annual turnover for the 12-month period corresponding to your R&D entity’s income year.
Important: Even if connected entities have different financial years, you must align their turnover calculation with your R&D entity’s income year period.
Step 5: Add It All Up (Minus Inter-Entity Transactions)
Sum all the annual turnovers but exclude transactions between the related entities to avoid double-counting.
🧮 R&D Tax Incentive Aggregated Turnover Calculator
Calculate your aggregated turnover and discover your R&D tax incentive benefits
1Your Main R&D Entity Details
2Connected & Affiliated Entities
Add entities where you have 40%+ control or affiliate relationships
3Calculate Your Benefits
💰 Your R&D Tax Incentive Calculation Results
Total Aggregated Turnover
Your R&D Tax Incentive Benefit
If Under $20M
43.5% Refundable Offset
Get cash back even in loss yearsIf Over $20M
Non-refundable with Intensity Premium
Tax offset only when profitableDisclaimer: This calculator provides estimates only. For accurate calculations and professional advice on R&D tax incentives, consult with qualified specialists.
Real-World Example: How One Company Saved Millions
Let me share a story that shows why getting this right matters so much.
We worked with a company that initially calculated their aggregated turnover at $24.5 million. This pushed them above the $20 million threshold, reducing their R&D benefits significantly.
But here’s what they discovered through proper analysis:
Initial Calculation | Amount |
---|---|
Main Entity Revenue | $13 million |
Connected Entity 1 | $5 million |
Connected Entity 2 | $2.5 million |
Government Grant | $4 million |
Total | $24.5 million |
After proper analysis and exclusions:
Revised Calculation | Amount |
---|---|
Main Entity Revenue | $13 million |
Connected Entity 1 | $5 million |
Adjusted Connected Entity 2 | $1.375 million |
Government Grant (Excluded) | $0 |
Total | $19.375 million |
This strategic recalculation brought them under the $20 million threshold, qualifying them for the refundable offset and saving them significant money.
Common Mistakes That Cost Australian Businesses Millions
Mistake 1: Ignoring Foreign Entities
Your overseas subsidiaries count towards aggregated turnover if they’re connected or affiliated. Many businesses forget to include foreign revenue, leading to incorrect calculations.
Mistake 2: Wrong Time Period Alignment
Connected entities with different financial years must have their turnover calculated for your R&D entity’s corresponding 12-month period. This alignment requirement trips up many businesses.
Mistake 3: Misunderstanding Control Thresholds
The 40% control test isn’t just about shareholding. It includes voting rights, distribution rights, and practical control arrangements.
Mistake 4: Including Non-Ordinary Income
Not all income counts towards annual turnover. Capital gains, certain government grants, and non-business income might be excluded.
Mistake 5: Double-Counting Inter-Entity Transactions
Transactions between connected or affiliated entities must be excluded from the aggregated turnover calculation.
Special Situations and Complex Scenarios 🔍
Trust Structures
Family trusts and unit trusts add complexity to aggregated turnover calculations. The key questions are:
- Who controls the trust?
- How are distributions determined?
- Are there common beneficiaries across multiple trusts?
Private Equity and Venture Capital
PE and VC ownership structures can trigger connected entity relationships, especially when:
- Investment funds have board representation
- There are common portfolio companies
- Control arrangements exist beyond shareholding
International Arrangements
Foreign entities complicate calculations because:
- Different reporting currencies need conversion
- Varying financial year ends require alignment
- Different accounting standards may apply
Partial Year Operations
If your R&D entity operated for only part of the income year, the annual turnover calculation becomes proportional. You’ll need to estimate what the full-year turnover would have been.

Recent Changes and What They Mean for You
R&D Intensity Measures (Post-July 2021)
For entities with aggregated turnover of $20 million or more, the offset calculation now depends on R&D intensity:
- Up to 2% intensity: Company tax rate + 8.5%
- Above 2% intensity: Company tax rate + 16.5%
This means higher R&D spending relative to total expenditure gets better rates.
ATO Guidance Updates
Tax Determination TD 2021/7 clarified how to handle different accounting periods for connected entities. This guidance helps ensure consistent calculation approaches across different business structures.
Practical Tips for Getting It Right Every Time ✅
Documentation Best Practices
Keep detailed records of:
- All entity relationships and ownership structures
- Control arrangements and voting rights
- Inter-entity transaction details
- Foreign entity financial information
Professional Assessment Indicators
Consider professional help when you have:
- Complex ownership structures
- International operations
- Trust arrangements
- Significant amounts at stake
Annual Review Process
Review your aggregated turnover calculation annually because:
- Entity relationships change
- New acquisitions or disposals occur
- Control arrangements evolve
- Revenue patterns shift
Tools and Resources for Accurate Calculations
Internal Assessment Checklist
Before finalising your calculation, verify:
- [ ] All connected entities identified (40% test)
- [ ] All affiliated entities mapped
- [ ] Correct time period alignment
- [ ] Inter-entity transactions excluded
- [ ] Foreign entity conversions accurate
- [ ] Documentation complete
When to Seek Professional Help
The calculation becomes complex when you’re dealing with:
- Multiple entity structures
- International arrangements
- Significant financial implications
- Unclear control relationships
At Innovellix, we specialise in helping Australian companies navigate these complex calculations and maximise their R&D tax incentive benefits.
The Future of Aggregated Turnover Rules
Emerging Trends
The ATO continues refining guidance around:
- Digital economy arrangements
- Cross-border structures
- Complex ownership models
- Technology sector peculiarities
Compliance Focus Areas
Recent ATO attention has focused on:
- Accurate entity relationship identification
- Proper time period alignment
- Comprehensive revenue inclusion
- Documentation standards
Strategic Planning for Optimal Outcomes 🎯
Structuring Considerations
When planning your business structure, consider:
- Impact of new entity acquisitions
- Timing of revenue recognition
- Control arrangement documentation
- International expansion effects
Cash Flow Management
Understanding your aggregated turnover position helps with:
- R&D project timing
- Investment planning
- Cash flow forecasting
- Tax strategy development
Industry-Specific Considerations
Technology Startups
Tech companies often face unique challenges:
- Rapid growth crossing thresholds
- Complex shareholding arrangements
- International expansion early in development
- Venture capital structures
Manufacturing Businesses
Manufacturing entities typically deal with:
- Supply chain entity relationships
- Joint venture arrangements
- International sourcing structures
- Equipment financing arrangements
Agricultural Operations
Agribusiness faces specific issues like:
- Family trust structures
- Seasonal revenue patterns
- Cooperative arrangements
- Rural financing structures
Maximising Your R&D Tax Incentive Claims
Strategic Timing
Consider timing strategies around:
- Entity restructures
- Revenue recognition
- R&D activity scheduling
- Claim lodgement timing
Documentation Excellence
Maintain comprehensive records for:
- Entity relationship evidence
- Control arrangement documentation
- Revenue calculation support
- Professional advice received
Regular Review Processes
Establish annual reviews covering:
- Entity relationship changes
- Control arrangement updates
- Revenue pattern analysis
- Threshold proximity assessment
Working with R&D Tax Specialists
What to Look For
Choose specialists who understand:
- Complex aggregated turnover calculations
- Entity relationship analysis
- ATO compliance requirements
- Industry-specific challenges
Questions to Ask
When selecting professional help, ask about:
- Experience with similar structures
- Understanding of recent changes
- Approach to complex calculations
- Client success stories
The R&D tax incentive specialists at Innovellix bring deep expertise in navigating these complex calculations while ensuring full compliance with Australian regulations.
Frequently Asked Questions 🤔
Does aggregated turnover include one-off sales?
Generally yes, if they’re ordinary income from business activities. However, capital gains and certain extraordinary items might be excluded.
What happens if I discover an error after lodging?
You can amend your R&D tax incentive claim, but it’s better to get it right the first time to avoid delays and complications.
How do currency conversions work for foreign entities?
Use appropriate exchange rates for the relevant periods, typically average rates for the income year.
Can professional fees for aggregated turnover calculations be claimed?
Professional fees for preparing R&D tax incentive claims are generally not eligible R&D expenditure.
Key Takeaways for Australian Businesses
Understanding aggregated turnover for the R&D tax incentive isn’t just about compliance – it’s about maximising the financial benefits available to your business.
Remember These Critical Points:
- The $20 million threshold determines refundable vs non-refundable benefits
- Connected entities (40% control) and affiliates must be included
- Time period alignment is crucial for accurate calculations
- Documentation and professional advice prevent costly mistakes
- Regular reviews ensure ongoing compliance and optimisation
Action Steps:
- Map all your entity relationships quarterly
- Document control arrangements clearly
- Align calculation periods properly
- Exclude inter-entity transactions correctly
- Seek professional guidance for complex situations
Getting aggregated turnover calculations right can mean the difference between receiving immediate cash flow and waiting years for tax benefits.
Don’t let calculation errors cost your business millions in lost R&D tax incentive benefits.
Understanding aggregated turnover for the R&D tax incentive requires attention to detail, but the financial rewards for getting it right make the effort worthwhile for every Australian company pursuing innovation.

Perth & Western Australia R&D Tax Incentive FAQ 🏙️
Q: I run a tech startup in Fremantle – does the aggregated turnover calculation work differently for WA businesses?
Nope, the rules are exactly the same across Australia.
Your Freo startup follows identical aggregated turnover calculations as a Sydney or Melbourne business. The $20 million threshold applies nationally, and all connected entities count regardless of where they’re located.
What makes WA unique is our strong mining and agriculture sectors often create complex entity structures that need careful analysis.
Q: My Perth mining services company has operations in the Pilbara – do remote site revenues count differently?
All your revenue counts, whether it’s from Perth CBD or remote Pilbara operations.
The location doesn’t matter for aggregated turnover calculations. What matters is:
- It’s ordinary business income
- It’s derived by your entity or connected entities
- It falls within the relevant income year
Many WA mining services companies get caught out by forgetting about their subsidiary operations across different mine sites.
Q: I’m part of a family farming operation near Geraldton with multiple trusts – how does this affect my R&D claim for agricultural innovation?
Family farm structures are tricky for aggregated turnover calculations.
Here’s what you need to check:
- Who controls each trust?
- Are there common beneficiaries across trusts?
- Do trusts act according to common directions?
Agricultural businesses often have:
- Multiple family trusts
- Various trading entities
- Equipment ownership structures
- Land holding arrangements
Each relationship needs proper analysis to determine if entities are connected or affiliated.
Q: My Northbridge software company just got VC funding from an East Coast fund – does this change my aggregated turnover?
It might, depending on the control arrangements.
VC funding often creates connected entity relationships when:
- The fund gets board control or significant voting rights
- There are 40% or more shareholding arrangements
- Common control exists across portfolio companies
Many Perth startups don’t realise their VC relationships can push them over the $20 million threshold through portfolio company aggregation.
Q: We’re a Joondalup manufacturing business with a subsidiary in Singapore – how do I include foreign revenue?
Foreign subsidiary revenue absolutely counts if it’s a connected entity.
For your Singapore subsidiary:
- Convert all revenue to Australian dollars
- Use appropriate exchange rates for the income year
- Align the calculation period with your Australian entity’s financial year
- Include all ordinary business income
WA’s strong trade relationships with Asia mean many local businesses have overseas operations that significantly impact aggregated turnover calculations.
Q: I operate from Osborne Park and my business partner runs a separate company in Balcatta – are we connected entities?
Depends on your ownership and control arrangements, not your locations.
You’re connected entities if either business:
- Controls 40% or more of the other’s voting power
- Has rights to 40% or more of distributions
- Has practical control through agreements
Many Perth business partners assume they’re separate just because they operate different companies in different suburbs. The control test is what matters.
Q: My Cockburn industrial business supplies three major mining companies – could these customer relationships affect my aggregated turnover?
Customer relationships alone don’t create connected entity status.
Being a major supplier doesn’t make you connected unless there’s:
- Ownership relationships (40% control test)
- Shared control arrangements
- Affiliate relationships where you act according to their directions
However, if any mining company owns part of your business or has control arrangements, that changes everything.
Q: We’re expanding from Perth to regional WA towns like Kalgoorlie and Broome – does this create new entities I need to consider?
Only if you’re setting up separate legal entities for regional operations.
Expanding your existing company doesn’t create new entities. But if you establish:
- Regional subsidiaries
- Joint ventures with local partners
- Separate companies for different locations
Then you’ll need to assess whether these are connected or affiliated entities.
Q: My Subiaco consulting firm works closely with a Cottesloe advisory business – when are we considered affiliates?
You’re affiliates if either business acts according to the other’s directions or wishes.
This isn’t about proximity or industry similarity. Look for:
- Shared decision-making processes
- Common business directions
- One business following the other’s strategic guidance
- Coordinated business activities
Just working in similar industries or nearby locations doesn’t create affiliate relationships.
Q: I’m considering moving my R&D operations from Perth to regional WA for government incentives – how does this affect aggregated turnover?
The location of your R&D activities doesn’t change aggregated turnover calculations.
Whether you conduct R&D in Perth CBD, Margaret River, or Karratha, the calculation remains the same. What matters is:
- Your entity structure
- Connected and affiliated relationships
- Total revenue across all entities
Regional incentives might offer additional benefits, but they don’t change the fundamental aggregated turnover rules.
Q: My Perth business operates through both a company and a trust structure – how do I calculate aggregated turnover correctly?
You need to assess each structure’s relationship to your R&D entity.
Common Perth business structures include:
- Trading company with family trust
- Unit trust holding operational company
- Discretionary trust distributing to multiple entities
Each arrangement requires analysis of control and affiliate relationships. The key is understanding who controls what and how decisions get made across your structure.
Q: Can I get local Perth-based help with complex aggregated turnover calculations?
Absolutely, and getting local expertise makes a huge difference.
Perth-based R&D specialists understand:
- WA’s unique industry structures
- Local business relationship patterns
- Regional expansion considerations
- Mining and agriculture entity arrangements
Innovellix specialises in helping Perth and WA businesses navigate these complex calculations while maximising their R&D tax incentive benefits.
Q: My Swan Valley agribusiness exports internationally – does export income count differently for aggregated turnover?
Export income counts exactly the same as domestic income.
Your Swan Valley operation’s international sales are ordinary business income that must be included in aggregated turnover calculations. It doesn’t matter if you’re selling:
- Wine to Asia
- Grain to Europe
- Beef to the Middle East
All export revenue counts towards your annual turnover calculation.
Q: We’re a Murdoch University spin-off company – how do university relationships affect our aggregated turnover?
University relationships rarely create connected entity status.
Most university spin-off arrangements involve:
- Licensing agreements
- Research collaboration
- Facility sharing
- Technology transfer
These relationships typically don’t trigger the 40% control test or create affiliate arrangements. However, if the university holds significant equity or control rights, that changes the calculation.
Q: My Welshpool logistics business serves multiple mining companies – could supply chain relationships create connected entities?
Standard supplier relationships don’t create connected entity status.
Being part of mining supply chains doesn’t make you connected unless there’s:
- Equity ownership (40% test)
- Control arrangements beyond normal commercial terms
- Shared ownership structures
- Common ultimate ownership
Many WA logistics and services businesses worry unnecessarily about customer relationships affecting their R&D calculations.
Q: What happens if I discover my aggregated turnover calculation was wrong after claiming the R&D tax incentive?
You can amend your claim, but it’s better to get it right first time.
If you discover errors:
- Contact the ATO about amendment options
- Prepare supporting documentation
- Consider professional assistance for complex corrections
- Understand potential interest and penalty implications
Getting professional help upfront prevents these costly correction processes and ensures you claim the maximum benefits available to your Perth business.