Edited version of private advice

Authorisation Number: 1052231931618

Date of advice: 22 March 2024

Ruling

Subject: Self-education expenses

Question

Is the expenditure incurred in undertaking an Executive Master of Business Administration an allowable self-education expense in the relevant income year?

Answer

Yes. Your self-education expenses are deductible as it is accepted that the study meets the requirements as set out in Taxation Ruling 2023/D1 Income tax: deductibility of self-education expenses incurred by an individual, and the Commissioner is satisfied that your study has the relevant connection to your income earning activities.

This ruling applies for the following period:

Year ended 30 June 20XX

The scheme commenced on:

XX XXX 20XX

Relevant facts and circumstances

You were working as a National Manager.

Your role oversees external and internal communications strategies in the company.

The role involves a number of strategic and operational elements, as well as team leadership and support for the broader organisation.

Your duties include:

•         Team leadership and oversight for the company.

•         Assign, supervise, and review the activities of communications staff.

•         Manage communications budgets.

•         Manage in-house communication courses.

•         Updates website as required.

•         Lead the design, development and implementation of the media, campaign strategy, communication and stakeholder engagement planning, drive website traffic, social, digital and online media strategy.

•         Production, approval and distribution of media releases and statements.

•         Regular engagement with media to ensure organisation's agenda is promoted through the media.

•         Act as media spokesperson for print, online and broadcast.

•         Organise and participate in media skills training.

•         Direct activities of external agencies, establishments, or departments that develop and implement communication strategies and information programs.

•         Establish and maintain effective working relationships with clients, government officials, and media representatives and use these relationships to develop new business opportunities.

•         Develop, implement, or maintain crisis communication plans.

•         Acts as Team Media Coordinator

•         Advise (or enact as appropriate) decision-making in a crisis, communication with industry stakeholders (including Board), review and approve internal and external communications and act as media spokesperson (unless determined otherwise).

•         Works with Crisis Management Team Lead, Coordinator, Media Coordinator and Log Keeper as required to ensure the team operates effectively and productively.

•         Project lead and oversight of industry communications and study tour projects as required.

•         Approval of quotes for freelance journalists/photographers, design, printing and distribution according to budget.

•         Ensure project requirements are met for communication of industry research through project outputs as required.

•         Oversee organisation's tender writing and grant writing processes.

•         Review and approve internal grant applications prior to CEO approval.

•         Review external documents, including project reports, prior to CEO approval.

•         Develop and maintain the company's corporate image and identity, which includes the use of logos and signage.

•         Assistance with in-house writing and design requirements.

On 20XX you undertook study of Executive Master of Business Administration (EMBA).

You incurred tuition fees during the 20XX income tax period.

The EMBA provided an accelerated leadership and management development course that assisted your current leadership role.

It also helped prepare you for future leadership roles and management opportunities.

The course had a strong focus on building practical skills and knowledge that you could immediately implement in your job.

Additionally, the course contained modules covering a wide range of leadership and operational topics that can be expected for current and future business leaders.

A description of the module topics you undertook in the course was provided.

The skills and knowledge you learned from the course allowed you to lead more strategic projects, contribute to more strategic-leveling planning and expand your responsibilities.

Since starting the course, your remuneration had increased in recognition of the increased responsibilities in leadership and strategy from the course.

You have since changed roles upon finishing your course which resulted in a further salary increase not accounting for more generous super contributions and other entitlements.

The new role is in a managerial role in a multi-national commercial company in a similar field but with more career opportunities for growth and increased responsibility.

This opportunity would have not been possible without the skills, knowledge and confidence gained from the EMBA.

Relevant legislative provisions

Income Tax Assessment Act 1997 section 8-1