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Corporate tax residency – There’s no Australian tax payable … is there?
Published on 01 Oct 20 by "THE TAX SPECIALIST" JOURNAL ARTICLE
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 Sandow, CTA, has over 30 years of experience as a tax professional, including 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. He has advised on mergers & acquisitions, tax governance, corporate tax, international tax, and employment tax issues. Tim is also the Partner leading BDO’s National Tax Risk & Ethics group. Tim is a CTA of The Tax Institute and a Chartered Accountant Fellow and the SA representative on the National Board of The Tax Institute. Tim is the current President of The Tax Institute and a regular presenter at numerous Tax Institute conferences and events. - Current at 11 December 2024
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