Private ruling: Self-education expenses
Date of advice: 20 August 2025
Published: 27 October 2025
Date scheme commenced: 1 July 20xx

Ruling: Q1: Can you claim a deduction for self-education expenses in relation to course fees under section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: No. This private ruling applies for the following period: Year ended 30 June 20XX Year ended 30 June 20XX The scheme commenced on: 1 July 20xx


Relevant legislative provisions: Income Tax Assessment Act 1997 section 8-1/p>

Reasons for decision: Summary: Work-related expenses generally fall for consideration under section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997). This section allows a deduction for losses and outgoings which are incurred while gaining or producing assessable income, unless the losses or outgoings are of a capital, private or domestic nature. The Commissioner's view on the deductibility of self-education expenses is contained in Taxation Ruling TR 2024/3 Income tax: deductibility of self-education expenses . In accordance with TR 2024/3, expenses of self-education will satisfy the requirements of section 8-1 of ITAA 1997 if: • a taxpayer's income-earning activities are based on the exercise of a skill or some specific knowledge, and the subject of self-education enables the taxpayer to maintain or improve that skill or knowledge ( FC of T v. Finn (1961) 106 CLR 60;(1961 12 ATD 348) ( Finn's Case ); or • the study of a subject of self-education objectively leads to, or is likely to lead to, an increase in a taxpayer's income from their current income earning activities in the future ( FC of T v. Hatchett (1971) 125 CLR 494; 71ATC 4184; (1971) 2ATR 557 ( Hatchett's Case ). Therefore, provided there is sufficient connection between a course of self-education and current income earning activities, you are entitled to claim a deduction for your self-education expenses. However, self-education expenses will not be deductible if the study is intended to: • enable you to get employment. • enable you to obtain new employment, or • to open a new income-earning activity (whether in business or in your current employment). | Detailed Reasoning - Course Fees: Course fees to attend a university or approved higher education provider are deductible only where you are enrolled in a full fee-paying place (where the government does not pay any part of your fees). You cannot claim a deduction for course fees in respect of a Commonwealth supported place (CSP). A CSP is a type of enrolment where the total cost of your study is split into 2 parts: • Subsidised amount - the Australian Government pays a subsidy directly to your education provider. This is not a loan and you do not pay it back. You cannot claim a deduction for the subsidised amount. • Student contribution amount - you pay the amount remaining, being the student contribution amount which you must pay by the census date either upfront or using a HECS-HELP loan, if you are eligible. HECS-HELP loans are repaid through the tax system once your income is above a certain threshold. You cannot claim a deduction for the student contribution amount you pay (either upfront or by way of a HECS-HELP loan) If you use borrowed money to pay for course fees, this will not affect the deductibility of those fees or when you can claim a deduction. However, you cannot claim a deduction for repaying the principal amount borrowed. Application to your circumstances : The Commissioner is satisfied that the course has the relevant connection with your employment. Therefore, the course does have the nexus with your employment. Your course fees are not an allowable self-education deduction under Section 8-1 of the ITAA 1997 as your course fees are paid under a Commonwealth Supported Place which means they cannot be an allowable deduction. You cannot claim a deduction for repaying the loan, either as part of your income tax assessment or as voluntary repayments. Further information about paying repayments of study and training support loans such as Higher Education Loan Program (HELP), including FEE-HELP and HECS-HELP can be found by searching ato.gov.au for 'QC 72166'.

Relevant facts: >On xx xx 20xx you became employed with employer A. | You were employed in the position on a full-time basis. | You decided to undertake further study to enable you to better perform your current position and to gain further skills that may lead to greater opportunities and an increased salary. | You enrolled in a post graduate degree and commenced studying on xx xx20xx. | The course teaching modules consisted of a number of topics: | You completed the course. | As a result of undertaking and successfully completing the course, your career within the employer A has progressed and your assessable income has increased. | You didn't receive a scholarship, allowance, or other assistance from employer A. | The course was paid via a Commonwealth Supported Fee Help Loan. | You have not been reimbursed by your employer for any of the self-education expenses. | On xx xx 20xx your employer provided a letter endorsing the application for post graduate study. | On xx xx 20xx as a result of completing the tertiary course you are now employed as a Xxx with employer A.