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This edited version has been archived due to the length of time since original publication.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

Authorisation Number: 1013046837015

Date of advice: 7 July 2016

Ruling

Subject: Self-education

Question

Are you entitled to claim a deduction for self-education expenses?

Answer

Yes

This ruling applies for the following period(s)

Year ended 30 June 2016

Year ending 30June 2017

Year ending 30 June 2018

Year ending 30 June 2019

Year ending 30 June 2020

The scheme commences on

The scheme has commenced

Relevant facts and circumstances

You are employed in a particular profession.

You have enrolled in an MBA course which was due to start in 20XX.

Your current duties include;

    • Stakeholder engagement

    • Contract management and procurement

    • Contractor mobilisation

    • Budgeting/scheduling

    • Reporting to management

The core units of your course are;

    • Introduction to management

    • Business economics

    • Leadership in a complex environment

    • Quantitative methods for business decision making

    • Accounting: A user perspective

    • Fundamentals of people management

The course may take a number of years to complete.

Relevant legislative provisions

Income Tax Assessment Act 1997 Section 8-1

Reasons for decision

Taxation Ruling TR 98/9 discusses the circumstances under which self-education expenses are allowable as a deduction. A deduction is allowable for self-education expenses if a taxpayer's current income earning activities are based on the exercise of a skill or some specific knowledge, and the subject of the self-education enables the taxpayer to maintain or improve that skill or knowledge (Federal Commissioner of Taxation v. Finn (1961) 106 CLR 60, (1961) 12 ATD 348).

Further, paragraph 26 of TR 98/9 states that expenses relating to self-education which are compulsory and unavoidable, as well as those for which a need can be shown in terms of fulfilling the requirements of the course, are regarded as being 'necessarily incurred' and are expenses of self-education.

In your case, it is accepted that the course you have undertaken will enhance the skills and knowledge that are required in the performance of your current employment duties.

Consequently, the self-education expenses incurred in undertaking this course have the necessary and relevant connection with the earning of your assessable income and are deductible under section 8-1 of the Income Tax Assessment Act 1997.


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