Private ruling: Deductibility of self education expenses
Date of advice: 5 May 2021
Published: July 2021
Ruling period: Year ended 30 June 2020
Date scheme commenced: 01 July 2019

Ruling: Q1: Are you entitled to a deduction for the fees incurred whilst completing an AHRI Practicing Certification Program under section 8-1 Income Tax Assessment Act 1997 (ITAA 1997)? | A1: Yes . Section 8-1 of the 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 discusses the circumstances under which self-education expenses are allowable as a deduction. A deduction is allowable for self-education expenses if a taxpayer's current income-earning activities are based on the exercise of a skill or some specific knowledge and the subject of the self-education enables the taxpayer to maintain or improve that skill or knowledge ( Federal Commissioner of Taxation v. Finn (1961) 106 CLR 60, (1961) 12 ATD 348. It is considered that the AHRI Practicing Certification Program sufficiently relates to and improves upon the skills you use in your current income producing activities.

Relevant facts and circumstances: You are currently employed Your department is responsible for supporting and assisting your employer to achieve its long term strategic objectives. The Department is accountable for developing and ensuring an effective and high performing workforce. In this role you are required to: • provide expert HR advice and solutions to key clients across the organisation • provide evidence-based best practice generalist HR advice to standardise HR practice and build capacity and capability • provide strong generalist and strategic HR advice to inform the development, implementation and evaluation of a broad range of complex HR change management projects You are undertaking an AHRI Practicing Certification Program to gain recognition as a Certified HR Practitioner. This certification is nationally recognised and encompasses a broad range of knowledge and skills required for contemporary professional HR practitioners. You have advised the course consists of four Units for which you received "recognition of prior learning" via the training provider for the first three units. You were required to complete the fourth unit to gain your accreditation. On completion of the certification you intend to continue to work for your employer The training and recognition have been identified to directly relate to your current job role.

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