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In what circumstances are individuals and companies treated as residents of Australia

Home, - Explain the Income Tax Assessment Act

Question - For tax purpose, in what circumstances are individuals and companies treated as residents of Australia? Explain based on the Income Tax Assessment Act 1936 (Cth) and relevant case law.

Answer -

As per Income tax assessment Act 1936, individuals are treated as resident of Australia for the purpose of taxation, if one of the following conditions are met:

1. The individual always lived in Australia.

2. The individual has come to Australia with the intention of living in Australia permanently.

3. The individual has been continuously in Australia for more than 180 days or 6 months and during this period he mostly worked in one job and lived at one place.

4. The individual is an Australian citizen who has gone abroad for a temporary period and does not intend to live there on a permanent basis.

5. The individual is a foreign student, who is visiting Australia for study purpose and who is enrolled in a course that is of a duration of more than 180 days or six months.

As per the Income Tax Assessment Act, 1936, companies are treated as resident of Australia for the purpose of taxation if one of the following conditions are met:

1. The company is incorporated in Australia.

2. The company is not incorporated in Australia but it has business in Australia and its central management and control is from Australia or its shareholders who hold majority voting rights are Australian residents.

In the case of Commissioner of Taxation v Pike [2020] FCAFC 158, the Full Federal Court held that if an individual who is an Australian resident is working abroad for many years and has a house in Australia where his family resides then this means that the individual has no intention of moving permanently out of Australia. Therefore, the court ruled, that the individual should be treated as a resident of Australia for the purpose of taxation, during the period he lived abroad. The essence of this judgment is that the residency factor is very important when determining whether an individual is Australian resident for the purpose of taxation or not.


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