The Draft ruling correctly restates the position set out in AAT Case 67/96 96 ATC 598 (and subsequently applied in Small Claims Tribunal Case Norris v FCT) ie. that superannuation contributions and accounting fees for the preparation of Australian tax returns are not apportionable against foreign income for the purposes of sections 23AF and 23AG.
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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