Private ruling: Income tax exemption - sporting club
Date of advice: 3 December 2025
Published: 27 January 2026
Ruling period: Year ended 20 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Is the Club exempt from income tax under section 50-1 of the Income Tax Assessment Act 1997 (ITAA 1997) as club established for the encouragement of a game or sport under item 9c.1(c) in section 50-45 of the ITAA 1997? | A1: Yes, the Club is exempt from income tax under section 50-1 of the ITAA 1997 as it is a society, association or club established for the encouragement of sport under item 9.1(c) of section 50-45 of the ITAA 1997, satisfies the special conditions in Section 50-70 of the ITAA 1997, and is not an ACNC type of entity meaning section 50-47 of the ITAA does not apply.

Relevant facts and circumstances: The Club is an incorporated association. The Club is located in Australia, and its activities are conducted in Australia. The Club is not registered with the Australian Charities and Not-for-profits Commission (ACNC) as a charity. The Club is managed and controlled by a Board of Management (the Board) The Club is governed by a Constitution (the Constitution). The Constitution confirms the entity's not-for-profit status by containing clauses that outline: • objects of the club • how income and property are handled • the classifications of memberships available at the Club • dissolution of the Club

Relevant legislative provisions: Income Tax Assessment Act 1997 section 50-1 | Income Tax Assessment Act 1997 section 50-45 | Income Tax Assessment Act 1997 section 50-47