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Edited version of private ruling
Authorisation Number: 1011899210035
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Ruling
Subject: Income - scholarship
Question
Is the part-time scholarship you received exempt income?
Answer
No.
Relevant facts and circumstances
You are a part-time student, studying for a Graduate Certificate.
You received a scholarship, paid in 2 instalments.
You work full time.
Relevant legislative provisions
Income Tax Assessment Act 1997 Section 51-10,
Income Tax Assessment Act 1997 Section 51-35 and
Income Tax Assessment Act 1997 Section 6-5.
Reasons for decision
Detailed reasoning
Subsection 6-5(2) of the Income Tax Assessment Act 1997 (ITAA 1997) provides that the assessable income of a resident taxpayer includes ordinary income derived directly or indirectly from all sources during the income year. Money received from a scholarship is ordinary income.
If an amount is exempt income it is not included in the assessable income of a taxpayer under section 6-15 of the ITAA 1997.
Section 51-10 of the ITAA 1997 provides that income received by way of a scholarship, bursary, educational allowance or education assistance by a full-time student at a school, college or university is exempt from income tax.
The scholarship you received is not exempt from income tax because you are a part time student.
As the amount received is income according to ordinary concepts and not exempt under any provision of the ITAA 1997, the income will be assessable.
Other relevant comments
ATO ID 2001/227 was reviewed which took into account a scholarship paid to a part time university student. The scholarship was not exempt from tax.