Determining whether an item in a residential rental property is a separate depreciable property or part of the building is essential for tax compliance and claiming depreciation. Interpretation Statement IS 10/01 provides the Commissioner’s view and outlines a clear three-step test to classify such items.
The Three-Step Test
Step 1: Is the Item Attached or Connected to the Building?
- If the item is completely unattached, it is not part of the building.
- Plugged or wired items are considered unattached.
- If the item is attached, proceed to Step 2.
Step 2: Is the Item an Integral Part of the Building?
- Would the rental property be incomplete or unable to function without the item?
- Integral items are considered part of the building.
- If not integral, proceed to Step 3.
Step 3: Is the Item Part of the Building’s Fabric?
- Consider the nature and degree of attachment, as well as the difficulty and potential damage during removal.
- Items forming part of the building’s fabric are considered part of the building.
Examples from IS 10/01
Part of the Building
- Plumbing and Piping: Attached, integral.
- Electrical Wiring: Attached, integral.
- Internal Walls and Doors: Attached, integral.
- Garage Doors: Attached, integral.
- Fitted Furniture (e.g., built-in wardrobes): Attached, not integral, but forms part of the fabric.
- Kitchen Cupboards: Attached, integral.
- Linoleum and Tiles: Attached, not integral, but forms part of the fabric.
- Heating/Air Conditioning Systems (built-in): Integral.
Separate Depreciable Property
- Bathroom Fittings and Furniture: May be argued as a separate asset depending on attachment.
- Freestanding Wardrobes and Cupboards: Not attached.
- Carpet: Attached, not integral, not part of the fabric.
- Blinds: Attached, not integral, not part of the fabric.
- Water Heaters and Hot-Water Cylinders: Not attached.
- Heating/Air Conditioning Systems (not significantly attached): Separate asset.
IS 10/01 provides a structured framework, helping property owners navigate this aspect of tax compliance effectively.
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