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This edited version has been archived due to the length of time since original publication.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.

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Edited version of your written advice

Authorisation Number: 1051256024877

Date of advice: 6 August 2017

Ruling

Subject: Are you conducting a business as a soccer coach?

Question 1

Are you in business as an elite soccer coach?

Answer

Yes

This ruling applies for the following periods:

Year ending 30 June 2017

The scheme commences on:

1 July 2016

Relevant facts and circumstances

You are employed full time in an unrelated occupation.

You have an interest in sport and have established contacts with sport clubs locally and overseas.

Outside of your employment you are a coach sport.

You registered a business name in 2016.

You are an accredited sport coach.

You conduct one training session per week in a local park for players aged between 10-16 years to help the young people improve their sport skills. You supply equipment and shirts at these training sessions.

You are remunerated at each session. The participants don’t sign any contract with you and their attendance at your training sessions is optional.

You also conduct a paid private training session with one player every fortnight.

You coach a development squad of around 20 players at a local club. You are paid an annual fee by the club. You anticipate your services as a coach will be also be required in 2018.

As a coach for this club, you run a coaching session one week during the soccer season and twice a week off season. Each session runs for 1-1.5 hours.

As part of your agreement to coach, you provide the following services:

You are intending to take some elite young players overseas to show case their skills to international clubs. You have designed packages for parents of the children to purchase, that include transport and accommodation or a training package. You will accompanying the parents and young people and would like to claim your travel, accommodation and other expenses in organising the training and game sessions.

You attract players through informal contacts and your reputation; however you will be developing social media pages in late 2017-18 to promote your organisation.

Relevant legislative provisions

Income Tax Assessment Act 1997 Section 6-5

Income Tax Assessment act 1997 Section 8-1

Reasons for decision

You are considered to be carrying on a business of soccer coaching due to the regular and systematic coaching activities you engage in, and the organisational and business-like manner in which you conduct your activities.

Taxation Ruling 1999/17 Income tax: sportspeople - receipts and other benefits obtained from involvement in sport (TR 1999/17), discusses the benefits received by individuals from involvement in sport.

TR 1999/17 states that where a person is receiving payment as a result of carrying on a business, those payments are assessable income under section 6-5 of the ITAA 1997. Consequently, you can deduct from your assessable income any loss or outgoing to the extent that it is incurred in carrying on a business for the purpose of gaining or producing your assessable income.


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