ATO Interpretative Decision
ATO ID 2014/9
Fringe Benefits Tax
Remote area holiday transport fringe benefit: gross taxable value - recipient's contribution-
This document incorporates revisions made since original publication. View its history and amending notices, if applicable.
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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you will need to ensure that the relevant provisions referred to in the decision have not been amended or repealed.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
For the purposes of working out the amount of the reduction of a remote area holiday transport fringe benefit under section 60A of the Fringe Benefits Tax Assessment Act 1986 ('FBTAA'), is '50% of the gross taxable value' of the fringe benefit calculated under paragraph 60A(1)(c) of the FBTAA before deducting any recipient's contribution?
Decision
No, for the purposes of working out the amount of the reduction of a remote area holiday transport fringe benefit under section 60A of the FBTAA, '50% of the gross taxable value' of the fringe benefit is not calculated under paragraph 60A(1)(c) of the FBTAA before deducting any recipient's contribution. The 'gross taxable value' is the amount that would be the taxable value of the fringe benefit if any reduction under subsection 60A(1) and section 62 of the FBTAA was ignored. The amount that would otherwise be the taxable value has already taken the recipient's contribution into account.
Facts
An employee works in a remote area of Australia. His employer pays $1,500 for the employee's return travel between the work locality and the employee's holiday destination in Australia. The employee contributes $250 towards the cost of the travel.
The payment of the employee's travel cost by the employer constitutes an external expense payment fringe benefit under paragraph 20(a) and subsection 136(1) of the FBTAA.
The provision of the expense payment fringe benefit is a remote area holiday transport fringe benefit for the purposes of subsection 143(2) of the FBTAA.
The employee's holiday destination is not the place where he resided before commencing his employment in the remote area or the capital city of the state in which the workplace is located. Therefore, subsection 143(3) of the FBTAA applies to the fringe benefit.
The employee is not provided with any other fringe benefit in relation to the holiday.
Reasons for Decision
All legislative references are to the FBTAA.
Section 60A provides a reduction in the taxable value of remote area holiday transport fringe benefits to which subsection 143(3) applies.
To work out the amount of the reduction under section 60A, paragraph 60A(1)(c) requires you to calculate '50% of the gross taxable value' of the remote area holiday transport fringe benefit(s).
In this case, where only one remote area holiday transport fringe benefit is provided, the 'gross taxable value' is determined under paragraph 60A(1)(a). Under that paragraph the 'gross taxable value' is so much of the taxable value of the fringe benefit as is attributable to transport, meals, or accommodation in relation to a particular holiday for a particular family member, ignoring any reduction under subsection 60A(1) and section 62. Section 62 does not apply in this situation.
The taxable value of an external expense payment fringe benefit is worked out under section 23. Under that section the taxable value of a fringe benefit to which paragraph 20(a) applies is the amount of the expense payment reduced by the amount of the recipient's contribution.
Under section 23 the taxable value of the external expense payment fringe benefit provided to the employee would be the cost of the travel less the recipient's contribution.
Therefore, the amount that would be the taxable value of the remote area holiday transport fringe benefit, ignoring any reduction under subsection 60A(1), is the cost of the travel less the recipient's contribution. This is the 'gross taxable value' of the fringe benefit.
As the recipient's contribution has already been taken into account in working out what would otherwise be the taxable value of the remote area holiday transport fringe benefit, for the purposes of working out the amount of the reduction under section 60A, '50% of the gross taxable value' of the fringe benefit is not calculated under paragraph 60A(1)(c) before deducting any recipient's contribution.
Under section 23 the taxable value of the fringe benefit provided to the employee is $1,250 ($1,500 less $250). Therefore, the 'gross taxable value' of the fringe benefit for the purposes of paragraph 60A(1)(a) is also $1,250. Under paragraph 60(A)(1)(c) '50% of the gross taxable value' of the fringe benefit is $625.
Amendment History
| Date of Amendment | Part | Comment |
|---|---|---|
| 31 July 2026 | Issue and Decision | Minor grammatical and punctuation changes |
| 31 July 2026 | Business Line | Updated to correct business line |
| 31 July 2026 | Date reviewed | Updated review date |
Year of income: Year ended 31 March 2014
Legislative References:
Fringe Benefits Tax Assessment Act 1986
paragraph 20(a)
section 23
section 60A
subsection 60A(1)
paragraph 60A(1)(a)
paragraph 60A(1)(b)
paragraph 60A(1)(c)
section 62
subsection 136(1)
subsection 143(2)
subsection 143(3)
Keywords
Expense payment fringe benefits
Fringe benefits tax
Remote area holiday transport fringe benefits
FBT taxable value
Recipients contributions
FBT employee contributions
Date reviewed: 20 July 2026
ISSN: 1445-2782
| Date: | Version: | |
| 13 February 2014 | Original statement | |
| You are here | 31 July 2026 | Updated statement |