Selected aspects of source and residency in the new millennium paper

Member Price: $57.00

Non Member Price: $75.00

Publication date: 16 Mar 07



This paper covers:

  • overview of the findings of Ralph and RITA on residency and source
  • review of selected difficult areas of the corporate residency rules, in particular a look at TR 2004/15
  • review of the difficulties in establishing source, including impact of the repeal of statutory source rules, e-commerce and DTAs.

Author profile:

Author Photo - Michael Dirkis CTA
Prof Michael Dirkis CTA
Michael is Professor of Taxation Law at the University of Sydney. He has a PhD on Australian international taxation and is a noted researcher, having authored Is it Australia's? Residency and Source Analysed (2005, Australian Tax Research Foundation), as well as authoring and co-authoring over 590 publications and papers. From May 1999 until October 2009 he was, as Senior Tax Counsel for the Taxation Institute, in the forefront of the all major tax reform and taxation administration reforms. He continues his involvement as a member of the Treasury's Tax Treaties Advisory Panel and the Education Committee of the Tax Practitioners Board. He was awarded the Australasian Tax Teachers Association's Graham Hill medal in recognition of his "outstanding contribution to the teaching of taxation law and policy" on 21 January 2010.
Current at 29 October 2012
Click here to expand/collapse more articles by Dr Michael DIRKIS.


This was presented at 22nd National Convention: Tackling Tax.

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