Preamble
No. The mere fact that a taxpayer travels from their home or usual workplace to a property where the taxpayer carries on a business of primary production does not automatically mean that a full deduction is available for the cost of the trip. The purpose of the trip will usually determine whether the expenses related to it will be an allowable deduction. Individual circumstances will determine whether the total expense, a portion of the expense, or no expense is deductible under subsection 51(1), or sections 53 or 54 of the Income Tax Assessment Act 1936 .
Claims for income tax deductions for expenses incurred in travelling directly between places of employment or business are generally allowable (refer to Taxation Ruling IT 2199). However, this may be different if, for example, the primary production property could also be regarded as a second residence or weekend retreat. In these cases, the purpose of each trip will determine whether a deduction is allowable. For example, a trip to complete renovations on a house on the property is not deductible as the purpose of the trip is not to engage in an income earning activity.
Travel between home and a primary production property in order to perform or to supervise farming activities is generally considered to be for the purpose of transporting the person to the place where they commence their income producing activities. The High Court has stated in relation to 'home to work' travel: '...it may be said to be a necessary consequence of living in one place and working in another...' (per Williams, Kitto and Taylor JJ in Hayley v. FC of T (1958) 100 CLR 478 at 501). Expenditure on such travel is considered to be private or domestic and therefore not deductible.
However, a deduction is generally allowable for any trip where bulky farm goods and equipment are carried (see FC of T v. Vogt 75 ATC 4073; 5 ATR 274), unless there is a reasonably secure storage area on the property (see Case N78 81 ATC 403; (1981) 25 CTBR (NS) Case 32 ; Case Z22 92 ATC 230; Case 7944 (1992) 23 ATR 1189).
If a taxpayer travels from their home to inspect a remote primary production property, where they do not actually do the work, for example, where the property is rented to a tenant farmer, the expense will be an allowable deduction ( FC of T v. Green (1950) 81 CLR 313). If the taxpayer's home is also their base of operations for several farming or other businesses, travel expenses from the home to the primary production property will be deductible even if they supervise or carry out work on the remote property ( Garrett v. FC of T 82 ATC 4060; 12 ATR 684), unless the taxpayer had a private or domestic purpose for the trip.