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Limitations of deductions for employees and office holders
(Interpretation Note 13)
This interpretation note was issued on 15 March 2011. Its
purpose is to clarify the deductions that may be claimed by
employees and office holders.
Section 23(m) of the Act prohibits the deduction of certain
expenses incurred by employees or holders of office, unless
specifically permitted, against their general income derived. The
prohibition applies to expenses, losses and allowances incurred in
the course of employment, or by an office holder, that would
otherwise have been deductible under section 11(a).
The term "employment" should be strictly interpreted
as it connotes a master-servant relationship, which, for example,
excludes independent contractors. Furthermore, directors of
companies, judges and persons in governmental positions are
typically regarded as "holders of office" and are thus
subject to the provisions of
