Private ruling: Deductions - self-education
Date of advice: 15 February 2023
Published: 3 April 2023
Ruling period: Year ended 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Are you entitled to a deduction for self-education expenses incurred in undertaking two training programs through an Institute? | A1: Yes.

Relevant facts and circumstances: You are employed as a medical professional. During the 20XX financial year, you undertook training programs through an Institute. You provided a letter form the employer (the letter) stating that the trainings are relevant to your role. The trainings were supported by your employer through approval of study leave and partial reimbursement for the course. You paid for the trainings.

Relevant legislative provisions: Income Tax Assessment Act 1997 Section 8-1

Reasons for decision: Summary: Section 8-1 of the Income Tax 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 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 Income tax: deductibility of self-education expenses incurred by an employee or a person in business discusses the circumstances under which self-education expenses are allowable as a deduction. Self-education expenses are deductible where: No deduction is allowable for self-education expenses if the study is: Paragraph 41 of TR 98/9 describes the example of Barry, a trainee accountant, who is studying commerce part-time at university. He is allowed a deduction for the costs associated with the course because the course enables Barry to maintain or increase the specific knowledge required in his current position and to carry out his duties more effectively. TR 98/9 goes on to say that if a course of study is too general in terms of the taxpayer's income-earning activities, the necessary connection between the self-education expense and the income-earning activity does not exist meaning that no deduction for self-education expenses would be allowable under section 8-1 of the ITAA 1997. | Detailed Reasoning - Application to your circumstances: In your role as a medical professional, the trainings are relevant to your role. The trainings were also supported by your employer through approval of study leave and partial reimbursement for the course. It is accepted that the trainings meet the requirements detailed in Taxation Ruling TR 98/9 therefore you are entitled to a deduction for self-education expenses.

the taxpayer's income-earning activities are based on the exercise of a skill or specific knowledge and the subject of the self-education enables the taxpayer to maintain or improve that skill or knowledge, or | the study of the subject of self-education objectively leads to, or is likely to lead to, an increase in the taxpayers' income from their current income-earning activities in the future. | to enable the taxpayer to get employment | to obtain new employment, or | to open up a new income-earning activity (whether in business or in the taxpayer's current employment).