Private ruling: Self-education expenses
Date of advice: 19 August 2022
Published: November 2022
Ruling period: Year ended 30 June 20XX | Year ending 30 June 20XX | Year ending 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Are course fees incurred for the study of a Master of Business Administration and Graduate Certificate in Supply Chain and Operations Management deductible as self-education expenses? | A1: Yes. Having considered your circumstances and relevant factors, the Commissioner accepts that the study you will be undertaking has a direct connection to your income producing activities as per Taxation Ruling TR 98/9 Income tax: deductibility of self-education expenses incurred by an employee or a person in business. The fees are deductible in the financial year they are invoiced, to the extent that they have not been reimbursed by your employer or a third party. Further information about self-education expenses including how to calculate your claim and what records you need to keep can be found by searching QC 3197 on ato.gov.au.

Relevant facts and circumstances: You are a full-time employee with a company that specialises in packaging and distribution. You hold a leadership position in the company and you are responsible for multiple work sites within Australia. You have accepted an offer to study a full-time Master of Business Administration (MBA), and you paid a non-refundable deposit to hold your place. This amount will be offset against the first fee instalment. The program structure is set over a 2-year period but is flexible and the program pace can be tailored to the needs of the student. You will commence the course in the second half of the 20XX calendar year and it's your intention to fast-track your studies. The MBA core subjects are: • Leadership • Data analysis> • Managing people • Managerial Economics • Innovation Bootcamp • Managerial ethics and the business environment • Financial accounting • Finance • Marketing • Operations • Business Strategy • Business in complex environments (Capstone). You will also need to complete six elective subjects as part of the program. You provided a detailed description of the core subjects and how they relate to the tasks you perform in your leadership role. Whilst undertaking your MBA you will also complete a part-time Graduate Certificate in Supply Chain and Operations Management. You intend to complete this course over two years concurrently with your MBA. The Graduate Certificate in Supply Chain and Operations Management is a specialist program designed to equip students with deeper knowledge and training in the field of supply chain and operations management. You must complete four compulsory subjects: • Supply chain management • Project management • Operations and process management and, • Global value chains. Your employer supports your desire to continue your professional development through studying the MBA and Graduate Certificate in Supply Chain and Operations Management and have arranged for you to work flexibly so that you can fulfil your study commitments. Your employer advised the MBA and Graduate Certificate in Supply Chain and Operations Management will not only contribute to your performance in your current role but will also allow you to perform additional functions for the business, and they are extremely pleased to see you pursing a higher education which will assist you in growing into a more knowledgeable, resourceful, and greater contributor to the team. Studying these courses will likely lead to you be being awarded more responsibility and/or a promotion. You will not be using FEE-HELP and the courses will be entirely self-funded.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 8-1 | Income Tax Assessment Act 1936 section 82A