The Australian Taxation Office (ATO) has announced the release of draft Taxation Ruling TR 2021/D3 on the Commissioner's view on the circumstances in which a company's research and development (R&D) tax offset will be denied or reduced, because their R&D expenditure is not 'at risk'. When the final Ruling is issued, it is proposed to apply both before and after its date of issue. However, the Ruling will not apply to taxpayers to the extent that it conflicts with the terms of settlem…