ATO Interpretative Decision

ATO ID 2002/856

Income Tax

Income - Graphic designer and income averaging
FOI status: may be released

This version is no longer current. Please follow this link to view the current version.

  • This document incorporates revisions made since original publication. View its history and amending notices, if applicable.

CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision.

This ATOID provides you with the following level of protection:

If you reasonably apply this decision in good faith to your own circumstances (which are not materially different from those described in the decision), and the decision is later found to be incorrect you will not be liable to pay any penalty or interest. However, you will be required to pay any underpaid tax (or repay any over-claimed credit, grant or benefit), provided the time limits under the law allow it. If you do intend to apply this decision to your own circumstances, you will need to ensure that the relevant provisions referred to in the decision have not been amended or repealed. You may wish to obtain further advice from the Tax Office or from a professional adviser.

Issue

Is the taxpayer, a graphic designer, a special professional as defined in subsection 405-25(1) of the Income Tax Assessment Act 1997 ('ITAA 1997')?

Decision

Yes. The taxpayer is a special professional as defined in subsection 405-25(1) of the ITAA 1997.

Facts

The taxpayer works as a freelance graphic designer. The taxpayer's income is not guaranteed and fluctuates from year to year.

Reasons for Decision

Division 405 of the ITAA 1997 applies special rates of tax on the above-average professional income of special professionals.

A special professional, defined in subsection 405-25(1) of the ITAA 1997, includes an author of a literary, dramatic, musical or artistic work. The note to this subsection states that expression 'author' is a technical term from copyright law. In general the 'author' of an artistic work is the artist, sculptor or photographer who created it.

The expression 'artistic work' is defined in section 10 of the Copyright Act 1968 and includes (whether the work is of artistic quality or not) a painting, sculpture, drawing, engraving or photograph.

The taxpayer as a graphic designer, is the author of an artistic work and as such is a special professional within the meaning given by subsection 405-25(1) of the ITAA 1997.

Date of decision:  2 August 2002

Year of income:  Year ended 30 June 1999 Year ended 30 June 2000 Year ended 30 June 2001

Legislative References:
Income Tax Assessment Act 1997
   Division 405
   Subsection 405-25(1)

Copyright Act 1968
   Section 10

Keywords
Graphic artists
Income averaging

Business Line:  Small Business/Individual Taxpayers

Date of publication:  23 August 2002

ISSN: 1445-2782

history
  Date: Version:
You are here 2 August 2002 Original statement
  24 April 2015 Updated statement
  5 January 2017 Archived