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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 private advice

Authorisation Number: 1051862541756

Date of advice: 9 July 2021

Ruling

Subject: Income - assessable prize

Question

Is the prize money you received assessable income under section 6-5 or section 6-10 of the Income Tax Assessment Act 1997?

Answer

No. The prize relates to the work you did before you came to Australia.

You did not rely on the receipt of the prize money for your regular maintenance. It was a one-off award, received with no expectation that it would recur. As the award amount was paid in addition to any regular income you may receive it is accepted that you did not rely on it for your regular maintenance.

The prize was not received in accordance with any employment or services rendered to your Australian employer (or work done while their employee). The awarding of the prize is not associated with any particular outcome you are required to achieve or any services you are required to provide. It is therefore considered that the prize money is not provided in respect of any employment or services you have rendered.

This ruling applies for the following period:

Year ending 30 June 2021

Year ending 30 June 2022

The scheme commences on:

1 July 2020

Relevant facts

You completed a thesis in 20xx at an overseas university before commencing employment in Australia.

You published a book titled book A and some shorter journal articles in 20XX which was based on your thesis.

You are now an academic at an Australian university.

You were nominated for the 'X' prize by your colleague in 20XX. The nomination highlighted the public discussion that had been generated in academic journals and the mainstream media as a result of your book.

There are strict nomination criteria which you met.

You were awarded the Prize in 20XX.

The prize is competitive and no employee has an expectation of winning the prize.

The prize committee can determine not to award the prize in any given year if appropriate.

A number of prizes are awarded each year.

Relevant legislative provisions

Income Tax Assessment Act 1997 section 6-5

Income Tax Assessment Act 1997 section 6-10

Income Tax Assessment Act 1997 section 10-5

Income Tax Assessment Act 1997 Section 15-2