Edited version of private advice

Authorisation Number: 1051992414715

Date of advice: 15 June 2022

Ruling

Subject: Work related expenses - self education

Question

Are the expenses you incurred in completing the PGA Membership Pathway Program deductible?

Answer

Yes. The expenses you incurred in completing the PGA Membership Pathway Program are deductible to the extent to which the expenses have sufficient connection to your income earning activities and they are not of capital, private or domestic in nature.

This ruling applies for the following period:

Year ended 30 June 20XX

Year ending 30 June 20XX

Year ending 30 June 20XX

Year ending 30 June 20XX

The scheme commences on:

1 January 20XX

Relevant facts and circumstances

You work for a Golf Course as a Trainee and commenced this role in January 20XX, earning salary and wages for this role.

Prior to the Trainee role, you were employed by the same Golf Course as a Pro-Shop Assistant fulltime.

You have no current qualifications.

You commenced the PGA Australia Membership Pathway Program as part of your employment as a Trainee. The course is a prerequisite for the employment as a Trainee.

You became a Trainee at the beginning of undertaking the course. You had been working fulltime with this same employer before starting this education course and trainee role.

The PGA Membership Pathway Program has three components:

1.    Academic Program

2.    Workplace Experience, and

3.    PGA Playing requirements

Your employer provides flexibility in work hours to allow you to complete the course work, including certain number of hours on a Monday to compete in compulsory Golf events as part of the course.

The course requires a minimum number of hours per week of working at the Golf course, with 4,000 hours of work required to be completed to be eligible to graduate.

The Golf Club and local golf professionals at the golf course endorsed you as a trainee to be able to enrol in the PGA Program.

Your duties as a Trainee include:

•         High level of customer service & sales assistance

•         Assist with Golf Development programs for Juniors, Ladies and Men

•         Assist with Club fitting services (drivers, Woods, Irons, Wedges, Putters)

•         Equipment repairs (reshaft, regrip, Swing Weighting, Spine Aligning, loft and lie

•         adjustments)

•         General Golf Services and Shop duties

•         Maintenance and cleaning of Cart Fleet

•         Range Ball Pickup

•         Administering member competitions

•         Managing social golf tee times

•         Maintaining the Golf Shop to a high standard of cleanliness and presentation

•         Assisting with Golf Operations duties (rostering, leave management)

•         Administration of timesheets

•         General pro shop duties, including opening and closing

•         Golf shop sales

•         Competition starting and green fee collection

•         Till operations and balancing of daily takings

The subjects you are undertaking as part of the course are as follows:

•         MPP001 Membership Pathway Program Induction

•         CO101 Laws and Principals of Golf Coaching

•         GD201 Branding and Social Media

•         GD101 Planning to be a PGA Professional

•         PL101 Responsibilities of Elite Athletes

•         TSE201 Training School One Evaluation

•         CO102 Club Based Coaching Programs

•         GD102 Engaging with the Golf Industry

•         CO103 Motor Learning and Technique Analysis

•         GD103 Junior Development

•         PL102 Golf Conditioning & Coaching Unsupervised

•         PL103 On Course Tactics and Strategies

•         PL104 Rules of Golf

•         MA101 Communication in the Workplace

•         SB101 Managing Stock in the Pro Shop

•         SB102 Sales and Merchandising

•         MA102 Managing Customers and Stakeholders

•         SB103 Delivering Pro Shop Services

•         MA103 Gold Facility Operations

•         SB104 The Value of a PGA Professional

•         PL201 Sport Science for Improved Performance

•         CO202 Coaching Technology and Equipment

•         GD202 Inclusive Golf

•         PL202 Planning to Improve

•         CO203 Coaching Gold Skills

•         GD203 Engagement Through Golf Events

•         Community Instructor - MyGolf Club Module

Once you complete the PGA Membership Pathway Program, you will be eligible for Full Membership (Vocational) of the PGA. It is anticipated that the course will be completed in December 20XX.

Full PGA (Vocational) membership will allow you to accelerate your career path in full management of golf courses as well as providing skills and knowledge for the role you are currently employed in.

In January 20XX you incurred education fees as required under the academic requirements of the PGA program.

Between January 20XX and June 20XX, you incurred costs in relation to travel, accommodation, golf equipment, golf course green fees and tournament entry fees in relation to meeting the PGA playing requirements prescribed under the program.

No reimbursement of expenses has been received from your employer. You funded all costs from personal income and savings.

Certain PGA tournaments award prize money winnings. To be paid prize money competitors must have an ABN. You registered an ABN for this purpose. You earned prize money while playing in tournaments.

You are not pursuing the PGA Membership Pathway Program to become a professional golf player.

Relevant legislative provisions

Income Tax Assessment Act 1997 (ITAA 1997) Section 8-1

Reasons for decision

Legislative references are to the Income Tax Assessment Act 1997 unless otherwise specified.

Section 8-1 allows a deduction for all losses and outgoings to the extent to which they are incurred in gaining or producing assessable income, except where the outgoings are of a capital, private or domestic nature, or relate to the earning of exempt income.

Taxation Ruling TR 98/9 explains how section 8-1 applies to self-education expenses. Self-education expenses must have a clear and relevant connection to your current income earning activities to be deductible. To show this connection it must be demonstrated that:

•         The self-education helps you maintain and increase the knowledge and skills you use in your income earning activities; or

•         The self-education is likely to lead to an increase in income from your current income earning activities.

However, the self-education expenses will not be deductible if the study is to enable you to open up a new profession or occupation and get a new employment.

TR 98/9 provides (at paragraph 23) the types of self-education expenses which are allowable subject to the general tests in section 8-1. The ruling also provides (at paragraph 24) the types of self-education expenses which are not allowable.

Allowable self-education expenses are deductible in the income year in which they are incurred.

Application to your circumstances

Education expenses

In your circumstances, you incurred education expenses for the subjects you're undertaking under the academic program component of the PGA Membership Pathway Program. It is considered that the subjects undertaken have sufficient connection to your income earning activities in your Trainee role. Therefore, the education expenses you incurred in undertaking the required subjects to be able to complete the academic program component are deductible.

Other expenses

You also incurred other expenses in complying the PGA playing requirements of the PGA Membership Pathway Program as follows:

•         Purchase of Golf equipment such as golf clubs, gold club shafts, golf bag and other items

It is considered that the purchase of these items maybe of capital, private or domestic in nature. Therefore, a reasonable apportionment is required to claim a deduction for these items to the extent to which the expenses incurred have sufficient direct connection to your income earning activities. The private portion will include the use of the equipment for your own private activities. These include playing golf socially and for practising in preparation for the compulsory events under the PGA Membership Pathway Program. The costs and/ or depreciation of golf equipment which are attributable to your private use would not be deductible.

•         Travel to attend and compete in PGA Tournaments and other fees

Travel expenses incurred which are directly attributable to attending and competing compulsory golf tournaments under the PGA Membership Pathway Program are deductible. Entry fees to compulsory tournaments are also deductible. Any private portion on golf course green fees won't be deductible. Meal expenses incurred where you're not required to stay overnight away from home, will also not be deductible. If you travel to another location for self-education purposes and you have established a new home, no deduction will be allowed on accommodation and meal expenses you incurred.

Other matters

Prize money earned from playing in tournaments as part of the PGA playing requirements of the PGA Membership Pathway Program would form part of your assessable income in the income year you derived the prize money.

Deductibility of expenses incurred in completing the PGA Membership Pathway Program is subject to meeting the substantiation requirements in Division 900.