Company age limits for accessing the refundable RDTI offset should not be introduced. These incorrectly presume that an R&D-intensive company will reach commercial maturity within ten years, and penalise ‘deep tech’ type industries with long R&D project cycles.

Supporting R&D activities should not be removed from RDTI eligibility. These activities are integral to R&D projects and a recognised in the incentive schemes of peer economies. Their withdrawal will reduce Australia’s competitiveness for R&D investment and discriminate against industries where supporting activities make up a larger proportion of overall R&D expenditure.

To the extent that government wishes to simplify the RDTI scheme by removing the distinction between core and supporting activities, it must broaden the concept of core activity to ensure the overall scope of eligible activity is competitive with international standards.