This paper covers:
- question 1: do you foresee any implementation and ongoing compliance challenges arising from the proposed calculation of R&D intensity?
- question 2: does the proposed method of calculation of R&D intensity pose any integrity risks?
- question 3: could total expenditure be aggregated across a broader economic group? would this create any implementation and ongoing compliance challenges?
- question 4: does the definition of clinical trials for the purpose of the R&DTI appropriately cover activities that may be conducted now and into the future?
- question 5: does the proposed finding process represent an appropriate means of identifying clinical trials expenditure for the purposes of the $4 million refund cap?
- question 6: do the draft feedstock and clawback provisions give rise to any unintended consequences that need to be addressed?