Private ruling: Self-education expenses
Date of advice: 28 October 2025
Published: 15 December 2025
Ruling period: Year ended 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Are you entitled to a deduction for unreimbursed transport expenses incurred in daily travel between your places of residence and your locations of employment under section 8-1 of the ITAA 1997? | A1: No. | Q2: Are you entitled to a deduction for unreimbursed transport and accommodation expenses you incurred while undertaking a compulsory placement at Location A under section 8-1 of the ITAA 1997? | A2: Yes. | Q3: Are you entitled to a deduction for unreimbursed transport and accommodation expenses incurred to attend on-campus exams at campus X under section 8-1 of the ITAA 1997? | A3: No. | Q4: Are you entitled to a deduction for unreimbursed expenses you incurred to attend a student association conference and university skills night under section 8-1 of the ITAA 1997? | A4: Yes. | Q5: Are you entitled to a deduction for unreimbursed expenses you incurred to purchases textbooks, a computer monitor, digital learning resource subscriptions and student association membership fees under section 8-1 of the ITAA 1997? | A5: Yes.

Relevant facts and circumstances: On XX 20XX, you commenced studying a combined degree program (The Program) at a university, a Commonwealth-supported place. On XX 20XX, you gained employment with your current employer. You are employed full-time as a trainee and you are paid in accordance with your employer's pay and conditions. Your primary income producing activity as a trainee is to attend all classes and placements of The Program and complete all coursework required to successfully completed your combined courses. It is a requirement of The Program, and your employment by extension, that you physically attend every scheduled university session or placement. You are required to pay your university's tuition fees, then your employer reimburses that amount to you. From XX 20XX, you commenced third year of study and your residence was in university's campus X. From XX 20XX to XX 20XX, you were required to travel from your residence to campus X or campus Y attend classes few times a week. From XX 20XX to XX 20XX, you resided at Location Z with your family member. From XX 20XX to XX 20XX, you undertook a training placement at Location A over 200km away from your then-current home address. You stayed in accommodation at the location of the placement for the duration of placement and incurred accommodation expenses. From XX 20XX to XX 20XX, you were required to complete a placement at a location close to your current residential address. Your placements in the 20XX calendar year were allocated by the university. During XX 20XX, you stayed at the university's campus X to attend end of year on-campus exam. You incurred accommodation and transport expenses. Your employer would reimburse compulsory transport and other expenses directly relating to placements but you did not apply for the reimbursement for these expenses. You incurred expenses to purchase a textbook, computer monitor, professional skills question bank subscription, student association membership, and attend a university skills night. You also incurred Academic Conference Ticket, transport and accommodation expenses. This was an academic conference which was held for Student Association members only. This conference had a schedule comprising primarily academic and practical seminars with networking and social events also included in the Conference's schedule.

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

Reasons for decision: Detailed Reasoning - Detailed reasoning: Section 8-1 of the ITAA 1997 allows an employee can only deduct a work expense to the extent that: • it is incurred in gaining or producing assessable income • the expense is not a loss or outgoing of capital • the expense is not private or domestic in nature • the expense is not incurred in relation to gaining or producing exempt or non-assessable non-exempt income, and • another provision of the tax law does not prevent deduction of the expense. Accordingly, self-education expenses are deductible under section 8-1 to the extent that they are related incurred in gaining or producing your assessable income and are not capital, private or domestic in nature; or incurred in gaining or producing exempt or non-assessable non-exempt income; or prevented from being deductible by a specific provision in the tax law. Paragraph 12 of the tax ruling TR 2024/3 Income tax: deductibility of self-education expenses incurred by an individual stated that a deduction is not available for self-education expenses incurred to the extent they are reimbursed. Paragraph 155 of TR 2024/3 advised that where you carry out your employment duties at the place of education, the deductibility of the travel expense will be determined by TR 2021/1 Income tax: when are deductions allowed for employees' transport expenses? Paragraphs 15 - 17 of TR 2021/1 states that determining whether a transport expense is incurred in gaining assessable income requires consideration of the nature of the work as a matter of substance, listing the following factors which Commissioner takes into account in determining whether transport expense are incurred in gaining or producing assessable income and are therefore deductible under section 8-1 of the ITAA 1997: • the travel fits within the duties of employment, that is, the obligation to incur transport expenses arises out of the employment itself and not the employee's personal circumstances • the travel is relevant to the practical demands of carrying out the employee's work duties or role, that is the transport expenses are a necessary consequence of the employee's income-producing activity • the employer asks for the travel to be undertaken • the travel occurs on work time • the travel occurs when the employee is under the direction and control of the employer. Paragraph 21 of TR 2021/1 indicates that with limited exceptions, travelling expenses incurred when travelling between home and regular place of work are not deductible. Such costs are not incurred in the course of gaining or producing an employee's assessable income. This expenditure is regarded as a prerequisite to earning an employee's assessable income. Paragraph 26 of TR 2021/1 advises to determine the regular place of work it may be necessary to consider in more depth the contract of employment, customary practice, the nature of the work duties, where these duties commence and at what point in time the employee is under the direction and control of their employer in order to determine where the employee's regular place of work is. Paragraph 48 TR 2021/1 states that the mere fact that an employee lives a significant distance from their regular place of work does not make their transport expenses deductible, for example, if they are required to fly to attend work. In such instances, the transport expenses are incurred because the employee lives at a distance from their regular place of work, rather than the employment itself being the occasion for the expenses. The expenses are explained by where the employee choses to live in relation to the location of their regular place of work. As such, they are private expenses as opposed to being incurred in gaining or producing the employee's assessable income. | Detailed Reasoning - Application to your circumstances: You are student and you are also a trainee for your employer. The primary condition of your employment is that you must successfully complete your degree. It is accepted that there is a close connection between your self-education expense and your produce income activity. Therefore, you are entitled to deduct on your self-education expenses to the extent that you have not been reimbursed by your employer. You have lived at few locations of residence over the ruling period, in which time you attended income-producing activities in each location which required daily travel to and from the place at which you lived at that time. You were not required to travel between multiple work locations within a day and you attended each of the locations according to a defined schedule over which you had certainty. As such, the Commissioner considers that your regular places of work include the places of education you attended daily from the places you lived, such as university's campus, and other locations of study and training. Therefore, the transport expenses you incurred in daily travel to and from your places of residence to attend classes, exams, or other locations of study and training are not deductible under section 8-1 of the ITAA 1997. | Detailed Reasoning - Question 2: Are you entitled to a deduction for unreimbursed transport and accommodation expenses you incurred while undertaking a compulsory placement at Location A under section 8-1 of the ITAA 1997? | Detailed Reasoning - Detailed reasoning: Paragraphs 52 - 55 of TR 2021/1 explain that where the employee's duties of employment necessarily require them to work for the same employer at two or more locations that are geographically distant from each other, travel to the more distant location for the performance of employment duties may instead be an incident of the employment. In other words, the distance or remoteness of a place of work may course the need for the travel to be part of that for the employee is employed. Subject to the requirements of paragraphs 15 to 17 of TR 2021/1 (previously listed), the Commissioner will accept that travel to a secondary location of work which would typically require an overnight stay away from home and which cannot be attributed to an employee's choice of where to live, would be constructed as a necessary incident of the employment. Therefore, the cost would be deductible. | Detailed Reasoning - Application to your circumstances: You were required to attend to a compulsory placement at Location A, for which you incurred transport and accommodation expenses. The placement required you to sleep away from your residence for short periods of time to perform your income producing activities, and you were not reimbursed by your employer for the transport and accommodation expenses you incurred. You did not establish a new residence at this location, and returned to your home once your employment duties in this location had concluded. Therefore, the transport and accommodation expenses you incurred in relation to this placement are deductible under section 8-1 of the ITAA 1997. | Detailed Reasoning - Question 3: Are you entitled to a deduction for unreimbursed transport and accommodation expenses incurred to attend on-campus exams at campus X under section 8-1 of the ITAA 1997? | Detailed Reasoning - Detailed reasoning: Paragraph 25 of TR 2021/4 Income tax: and fringe benefits tax: employees: accommodation and food and drink expenses, travel allowances, and living-away-from-home allowances (TR 2021/4) indicates an employee cannot deduct accommodation expenses they incurred because due to their personal circumstances, they live far away from where their place of work is located. These expenses are living expenses and are not deductible. | Detailed Reasoning - Application to your circumstances: You made the choice to move residences from your on-campus accommodation to another location to live with a family member, and you returned to the campus to attend on-campus exams; over 100km from your residence at the time, for which you incurred travel and accommodation expenses. As you had no remaining employment obligations in the vicinity of your residence the Commissioner considers that the place of your exams was your regular place of work and the fact that you lived far away from that location was due to a personal choice to reside with a family member. Therefore, the travel and accommodation expense you incurred to attend on-campus exams is private in nature and as such, is not deductible. | Detailed Reasoning - Question 4: Are you entitled to a deduction for unreimbursed transport and accommodation expenses you incurred to attend the Academic Conference, and a university skills night, under section 8-1 of the ITAA 1997? | Detailed Reasoning - Detailed reasoning: The Commissioner accepts that expenditure incurred in relation to the attendance of courses, seminars and conferences is deductible if the subject of self-education is directly relevant to the taxpayer's current income-earning activities, particularly if the activities are based on the exercise of a skill or some specific knowledge which is maintained or improved by the subject of self-education. Paragraph 26 TR 2024/3 states that where your income-earning activities are based on the exercise of a skill or having specific knowledge, self-education expenses incurred to maintain or improve that knowledge or your ability to exercise those skills are deductible. | Detailed Reasoning - Application to your circumstances: You incurred expenses to attend in academic conference and university skills night. It is accepted that the subject of the conference and the university skills night are directly relevant to your current income-earning activities. Particularly your employment is based on the exercise of a skill or some specific knowledge which is maintained or improved by the subject of the conference and skills night at your university. You did not claim the reimbursement from your employer. Therefore, you can claim a deduction for these expenses you incurred under section 8-1 of the ITAA 1997, including accommodation and transport expenses you incurred to attend the conference. | Detailed Reasoning - Question 5: Are you entitled to a deduction for unreimbursed expenses you incurred to purchase a textbook, a computer monitor, digital learning resource subscriptions and Student Association membership fees under section 8-1 of the ITAA 1997? | Detailed Reasoning - Detailed reasoning: Paragraph 119 of TR 2024/3 allows you to deduct self-education expense for professional and trade journals, digital subscriptions and stationery, including pens, and photocopying. Paragraph 5-6 TR of 2000/7 Income tax: subscriptions, joining fees, levies and contributions paid to associations by individuals confirms that you can deduct joining fees are paid to a trade, business or professional association under section 25-55 of the ITAA 1997 and the periodic subscriptions one is deductible under section 8-1 of the ITAA 1997. | Detailed Reasoning - Application to your circumstances: You incurred expenses to purchase a textbook, a professional skills question bank subscription, a computer monitor and Student Association membership that you use 100% for self-education purpose. You did not apply for reimbursement from your employer. Therefore, you can claim a deduction for these expenses under section 8-1 of the ITAA 1997.