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Expatriates: Section 23AG exemption paper


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
Current at 21 November 2010
Belinda WRIGHT
Current at 18 September 2009 Click here to expand/collapse more articles by Belinda WRIGHT.

Current at 15 September 2009 Click here to expand/collapse more articles by Kristy WHITNELL.

Author Photo - Alana HAIDUK
Alana is a Senior Manager in PricewaterhouseCoopers' International Assignment Solutions (IAS) practice in Brisbane. She is a senior member of the Brisbane IAS, payroll services and employment taxes team. She has more than nine years experience with PricewaterhouseCoopers. The Brisbane IAS team specialises in advising on the expatriate tax and human resource issues for multinational organisations and their employees. Alana also has significant experience in developing remuneration and tax policies for many global organisations. Alana is responsible for the administration of a number of large expatriate programs in Brisbane and has considerable experience advising clients on general employment issues such as superannuation, fringe benefits tax and payroll tax. Alana also specialises in US taxes
Current at 30 April 2008 Current at 04 June 2008 Click here to expand/collapse more articles by Alana HAIDUK.

Justin LONG
Current at 18 September 2009 Click here to expand/collapse more articles by Justin LONG.


This was presented at Expatriates: Critical Tax & Super Issues .

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