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This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law.

You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4.

Edited version of your private ruling

Authorisation Number: 1012251224961

Ruling

Subject: Income from coaching activities

Question:

Are you assessable on the payments you receive for coaching?

Answer:

No

This ruling applies for the following period

Year ended 30 June 2012

The scheme commenced on

1 July 2011

Relevant facts and circumstances

You were approached by a local school to coach a sports team.

You were previously an elite sportsperson in this field.

You have no formal coaching qualifications, accreditations or certificates.

You are required to sign a 'statement by a supplier' declaring that the supply is made in the course of an activity done as a private recreational pursuit.

You are remunerated for your time on an hourly rate and paid by cheque on a fortnightly basis. Hours can vary, you have no set minimum or maximum hours you are required to work.

You work a number of hours per week. You are required to submit a time card each fortnight showing the hours you work.

No contract of employment is in place. You do not receive paid leave, sick leave. You are not eligible for long service leave.

You do not invoice the school for hours worked and do not quote an ABN.

The school is a not for profit organisation.

Relevant legislative provisions

Income Tax Assessment Act 1997 Section 6-5

Income Tax Assessment Act 1997 Section 6-10

Reasons for decision

Taxation Ruling TR 1999/17 discusses benefits received by individuals from involvement in sport.

The Ruling sets out the Commissioner's view as to whether these benefits are assessable income.

The Ruling applies to individuals who receive benefits through their involvement in sport, either as a participant or as an official, such as a referee or coach.

Paragraph 9 of TR 1999/17 states that the following types of payments are considered to be assessable income when paid to sportspeople:

In you case, we do not consider the payments you receive are derived in respect of employment or that you are an employee of the payer.

The payments you receive for coaching are not income in return for services that you provide but rather minor payments in appreciation for you undertaking this pastime.

You only coach for one school; your services are not offered to others. You do not rely on this type of work as your main source of income and you do not carry on the activity of coaching as a commercial activity. Your activities are carried out on a small scale and not in a business like manner. As such we do not consider you to be carrying on a business of coaching.

As such your payments are not assessable income under section 6-5 or section 6-10 of the Income Tax Assessment Act 1997.


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