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Corporate tax residency – There’s no Australian tax payable … is there?


This article looks back at the historical development of the corporate residency rules including some consideration of the old line of authority (eg Malayan Shipping v FCT) and the newer decisions (eg Bywater Investments Ltd v FCT). This is followed with analysis as to where we are currently at (especially TR 2018/5) and, most importantly, where we might be going in this space. In doing so, the key risk areas are identified and assessed, the central importance of board minutes is considered as is the critical impact of technology, and the interface with treaties, transfer pricing, capital gains tax and the controlled foreign rules is evaluated.

Author profile

Timothy Sandow CTA
Tim is an experienced tax professional with 25 years in the ‘Big 4’, he provides income tax related advice to a variety of private and large public companies as well as multi-nationals. In particular, Tim has advised many companies on mergers & acquisitions, tax governance, corporate tax, international tax, and employment tax issues, always maintaining a focus on practical commercial advice. One of Tim’s key skills is understanding complex tax issues and communicating these in a practical way enabling CFO’s, Boards and Business Owners to focus on the key opportunities and risks when making business decisions. Tim is currently the SA representative on National Council of The Tax Institute. - Current at 17 July 2020
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