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Edited version of private advice
Authorisation Number: 1052295689208
Date of advice: 23 August 2024
Ruling
Subject: Self-education expenses
Question
Are you entitled to a deduction for self-education expenses incurred in completing the course at a school under section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Answer
Yes - the self-education expenses for this course are deductible under section 8-1 of the ITAA 1997 as the expenses have sufficient connection to your income earning activities. Further information about self-education expenses can be found in TR 2024/3 Income tax: deductibility of self-education expenses incurred by an individual.
This ruling applies for the following periods:
Year ending XX June 20XX
Year ending XX June 20XX
The scheme commences on:
XX July 20XX
Relevant facts and circumstances
You are an Australian resident for tax purposes.
You are planning on completing the course offered by the school, commencing in May 20XX.
The course is expected to be completed in August 20XX.
You are currently employed as an Executive Director' and Chief Operating Officer' for an international company.
You are currently based in Country B on a full time basis.
Your responsibilities for your current roles include the following:
• Lead the organisation in meeting the company's environmental, health and safety system requirements.
• Set and deliver physicals, operating cost and capital budgets and forecasts to meet annual objectives whilst maximising value.
• Review performance and adjust to a changing market, by optimising production plans and monitoring performance to adjust those plans as required.
• Ensure the quality and effectiveness of engineering, and delivery services
• Influence product and technical development strategies through membership on key steering committees.
• Delivery of targets and actual performance by identifying opportunities, providing resources and executing action plans.
• Participate in the development of resource development strategies.
• Manage activity costs by developing cost management processes and financially responsible culture.
• Ensure the workforce is informed on direction and targets through a coordinated communication and re-engagement plan.
• Support the CEO in the management of relationships with external stakeholders through a coordinated approach including attendance at regular meetings.
The course offers the following three modules.
The first module is offered in-person in Country B. It comprises of the following units:
• Strategy, Digital Innovation, and Leadership - topics include customer value, market positioning, corporate strategy, product and service innovation, digital strategies, high-performance teams, leadership, and talent management.
The second module is offered virtually at home and in the workplace. It comprises of the following units:
• Independent Learning and Work on Big Business Challenge - complete an online course, Design Thinking and Innovation; work on a special project that addresses an important business challenge facing your organization; and apply program learning in your workplace.
The third module is offered in-person at the school campus and comprises of the following:
• Thinking Globally, Driving Local and Regional Growth, and Sustaining Success - obtain feedback on your project and explore topics including the intersection of business, government, and the international economy; growth strategies; marketing; financing; partnerships; governance; performance measurement; and corporate finance.
The cost to complete the course is $XX.
The cost for flights and accommodation to complete module three at the school campus is $XX.
You will not be in receipt of Austudy, ABSTUDY, Youth Allowance, HELP, or HECS to fund the course or associated costs.
You intend to remain in your current role at the completion of the course.
Your company supports you completing the course and engaging in continuous learning and skill enhancement.
Your company advises that completing the course could lead to a rise in income and wages for you.
No further incentives are provided by the employer to complete the course.
Assumptions
For the purpose of this ruling, it is assumed that the following actions will happen during the period of the ruling:
• You will incur the costs specified in this ruling.
• You will continue to work for the international company.
• Remain an Australian resident for tax purposes.
Relevant legislative provisions
Income Tax Assessment Act 1997 section 8-1