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Corporate residency issues in light of COVID-19 paper


This paper covers:

  • corporate residency case law and ATO guidance
  • proposals for changes to corporate residency rules considered by the Board of Taxation
  • implications for residency from COVID-related travel restrictions
  • interaction of residence with double taxation treaties and implications of the Multilateral Instrument
  • consequences of potential dual residence or migration of companies as a result of the corporate residency rules
  • insight into the challenges facing foreign incorporated companies today
  • options to manage tax risks and governance implications.

Author profile

Dr Dr. Julianne Jaques CTA
Dr Julianne Jaques, CTA, is a barrister specialising in taxation law. She has particular expertise in disputes involving complex commercial transactions and was counsel for the Commissioner in the Bywater matter in the High Court concerning corporate residency. Prior to coming to the Bar, Julianne spent 10 years in private practice with a major law firm and a major accounting firm. She is a Chartered Tax Adviser and a Chartered Accountant, and her doctoral thesis at the University of Melbourne was on the taxation of corporates. Julianne is a member of the Tax Practitioners Board and the Board of Taxation. In March 2020, Julianne was awarded Chartered Tax Adviser of the Year - Current at 16 December 2020
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This was presented at VIC 8th Annual Tax Forum Online .

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