Private ruling: Deductions - self-education expenses
Date of advice: 31 July 2025
Published: 29 September 2025
Ruling period: Year ending 30 June 20YY
Date scheme commenced: DDMMYYYY

Ruling: Q1: Are you entitled to a deduction for the self-education expenses you incurred to attend the retreat? | A1: No.



Reasons for decision: Summary: Section 8-1 of the Income Taxation Assessment Act 1997 (ITAA 1997) allows a deduction for all losses and outgoings to the extent to which they are incurred in gaining or producing assessable income. However, you cannot claim a deduction where the outgoings are of a capital, private or domestic nature. Taxation Ruling TR 2024/3 Income tax: deductibility of self-education expenses incurred by an individual discusses the circumstances under which self-education expenses are allowable as a deduction. Paragraphs 14-16 TR 2024/3 provides: • the words in section 8-1 are read as incurred 'in the course of' gaining or producing assessable income, rather than 'in connection with' or 'for the purpose' of deriving assessable income. • there must be a relationship, or close connection, between the expenditure and what it is that you do to produce your assessable income. • the expenditure must have a close connection to the performance of your employment the duties and activities. Paragraph 19 of TR 2024/3 explains your employer's encouragement to undertake the self-education is not, by itself, determinative of whether the expense is deductible. Paragraph 22 of TR 2024/3 provides you can claim a deduction for self-education expenses if either or both of the following apply: • Your income-earning activities are based on the exercise of a skill or some specific knowledge and the self-education enables you to maintain or improve that skill or knowledge. (Principle 1) • The self-education objectively leads to, or is likely to lead to, an increase in your income from your current income-earning activities in the future. (Principle 2) | Detailed Reasoning - Application to your circumstances: In your case, the retreat is too general and doesn't improve the skills and knowledge you require to be a junior doctor. While the name of the retreat isn't determinative, it is a factor we consider. The nature of the retreat is about general wellbeing, CPD planning and goal setting - not specific training to improve your skills and knowledge as a junior doctor. The retreat includes several optional recreation activities. These are private activities with no connection to your employment. We acknowledge the retreat allowed you to earn XX CPD hours and your employer supported you to attend. Together, these factors are not determinative of whether the expense is deductible. Further, you would not be deregistered if you didn't attend this particular retreat. We acknowledge there is a general link between the retreat and your job. However, the retreat does not improve the skills and knowledge you require to carry out your work duties. There is no close connection between your everyday work duties and the courses you completed at the retreat. There is an insufficient connection between your role as a junior doctor, and the retreat as to whether it maintains or improves your skills. Neither does it objectively lead to, or is likely to lead to, an increase in your income from your current income-earning activities in the future. We are not satisfied that your attendance at the retreat has the sufficient connection to your income earning activities. Therefore, you are not entitled to a deduction for the self-education expenses you incurred to attend the retreat.

Relevant facts and circumstances | In MMYYYY, you started your employment with a Health Department. | You are employed as a junior doctor. | At the time of the retreat, you worked part-time. | Details of your employment duties | As a junior doctor in a hospital, you work on wards and in the emergency department. Your duties include: | • assess and examine patients | • undertake clinical administrative duties such as preparing discharge summaries | • perform some medical procedures such as inserting intravenous cannulas | • request medical investigations. | A retreat for doctors (the retreat). | • information on continuing professional development (CPD) requirements | • optional nurturing activities | How the retreat relates to your employment | You must maintain medical registration with the Agency to maintain your employment as a medical practitioner. | You are required to complete a prescribed amount of CPD hours. | You advised the retreat helped you understand and plan your CPD requirements. It contributed to your required CPD hours. | Your employer encouraged you to attend the retreat and granted you paid professional development leave. | You were not reimbursed for the cost of the course or trip. | You didn't receive any bonus or reward from your employer for attending the course. | You travelled from XX (where you work and reside) to XX to attend the retreat. | The main purpose of the trip was to attend the retreat and earn your CPD hours. | You did not plan any other private activities (not included in the retreat) and were not accompanied by family or friends. | You did not meet up with family or friends the day before or after the retreat. | On DDMMYYYY (the day before the retreat), you flew to XX, collected a hire car, drove to XX, and rested in the accommodation that evening. | From DDMMYYYY to DDMMYYYY, you attended the retreat. | On DDMMYYYY (the day after the retreat), you flew back to your home. | You incurred the following expenses: | You achieved XX CPD hours on completion of the retreat. | You did not receive any government allowance to study (including ABSTUDY, Austudy or Youth Allowance). | You did not receive a taxable bonded scholarship. | Relevant legislative provisions | Income Tax Assessment Act 1997 section 8-1