This Taxation Determination is a 'public ruling' for the purposes of Part IVAAA of the Taxation Administration Act 1953 and is legally binding on the Commissioner. Taxation Rulings TR 92/1 and TR 97/16 together explain when a Determination is a public ruling and how it is legally binding.
Date of Effect
This Determination applies to years commencing both before and after its date of issue. However, this Determination does not apply to taxpayers to the extent that it conflicts with the terms of settlement of a dispute agreed to before the date of the Determination (see paragraphs 21 and 22 of Taxation Ruling TR 92/20).
1. No, except when paid by an employer as a cost of employing a person or where they form part of a business activity, as there would otherwise be no nexus between the expenditure and the derivation of assessable income.
2. A 'consumer loyalty program' is defined in Taxation Ruling TR 1999/6 'Income tax and fringe benefits tax: flight rewards received under frequent flyer and other similar consumer loyalty programs'.
Commissioner of Taxation
16 June 1999
NO NAT 98/6907-7
ISSN 1038 - 8982
deductions and expenses
frequent flyer benefits