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Expatriates: Section 23AG exemption paper

Published on 13 Aug 09 by QUEENSLAND DIVISION, THE TAX INSTITUTE

The government in their May budget announced the removal of this much utilised section of the 1936 Act which allowed for employment income of outbound expatriates to be exempt from Australian tax. This paper explores these amendments and the impact they will have on employees and employers.

The taxation impact on employers include PAYG, pay-roll tax and superannuation obligations and increased FBT costs. Given the changes employers will also face a loss of international competitiveness, increased assignment costs and reduced ability to attract employees on overseas assignments.

Employees will face greater issues such as double tax and the associated cashflow concerns. Accordingly, this paper also explores the alternatives available including the use of foreign income tax offsets and the use of double tax agreements.

Author profiles

Sally-Anne Horn
Sally-Anne is a Manager with PricewaterhouseCoopers - Current at 23 November 2016
Belinda Wright CTA
Belinda is a Director with PricewaterhouseCoopers. - Current at 28 June 2017
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Kristy Whitnell
Kristy is a Director with PricewaterhouseCoopers. - Current at 03 December 2015
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Alana Haiduk
Photo of author, Alana HAIDUK Alana is a Director in PwC’s Private Clients practice in Brisbane. She is the team leader of the Brisbane International Assignment Solutions, Payroll Services and Employment Taxes teams. She has more than 11 years experience with PwC. Alana is responsible for the administration of a number of large expatriate programs and has considerable experience advising clients on general employment issues such as superannuation, fringe benefits tax and payroll tax - Current at 05 November 2010
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Justin Long
Justin is a Senior Manager in PricewaterhouseCooper’s International Assignment Solutions (IAS) practice in Brisbane. Justin has been with PwC for over 7 years specialising in managing expatriate programs for multinational corporations, as well as advising on related topics such as international tax, expatriate policy, employment taxes, US personal tax and individual tax planning. Justin's experience with PwC includes a 3 year assignment with PwC in San Francisco, US specializing in US personal tax compliance and expatriate program coordination for US based multinational corporations.Justin is a Senior Manager in PricewaterhouseCooper’s International Assignment Solutions (IAS) practice in Brisbane. Justin has been with PwC for over 7 years specialising in managing expatriate programs for multinational corporations, as well as advising on related topics such as international tax, expatriate policy, employment taxes, US personal tax and individual tax planning. Justin's experience with PwC includes a 3 year assignment with PwC in San Francisco, US specializing in US personal tax compliance and expatriate program coordination for US based multinational corporations. - Current at 16 January 2013
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This was presented at Expatriates: Critical Tax & Super Issues .

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