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Edited version of private advice
Authorisation Number: 1052483326701
Date of advice: 3 December 2025
Ruling
Subject: Income tax exemption - sporting club
Question
Is the Club exempt from income tax under section 50-1 of the Income Tax Assessment Act 1997 (ITAA 1997) as club established for the encouragement of a game or sport under item 9c.1(c) in section 50-45 of the ITAA 1997?
Answer
Yes, the Club is exempt from income tax under section 50-1 of the ITAA 1997 as it is a society, association or club established for the encouragement of sport under item 9.1(c) of section 50-45 of the ITAA 1997, satisfies the special conditions in Section 50-70 of the ITAA 1997, and is not an ACNC type of entity meaning section 50-47 of the ITAA does not apply.
This ruling applies for the following period:
Year ended 20 June 20XX
The scheme commenced on:
1 July 20XX
Relevant facts and circumstances
The Club is an incorporated association.
The Club is located in Australia, and its activities are conducted in Australia.
The Club is not registered with the Australian Charities and Not-for-profits Commission (ACNC) as a charity.
The Club is managed and controlled by a Board of Management (the Board)
The Club is governed by a Constitution (the Constitution).
The Constitution confirms the entity's not-for-profit status by containing clauses that outline:
• objects of the club
• how income and property are handled
• the classifications of memberships available at the Club
• dissolution of the Club
Relevant legislative provisions
Income Tax Assessment Act 1997 section 50-1
Income Tax Assessment Act 1997 section 50-45
Income Tax Assessment Act 1997 section 50-47