International Taxation

Are you planning to work overseas for a short period or long term? Have you being relocated to Australia to head up a subsidiary of an overseas company? Do you conduct business overseas? If the answer is yes to any of these questions, then you need to consider your tax position from an international perspective.

In determining liability to Australian tax on the basis of residence or non-residence in Australia, it is necessary to consider not only the income tax laws, but also any applicable double taxation agreement (DTA).

Australia has DTAs with over 35 countries to avoid the incidence of double taxation.

Often income may be the result of a combination of several factors occurring in different places. For example, the immediate source of income may be the sale of goods in Australia. The fact that the goods were purchased, produced or manufactured outside Australia would also be relevant in determining the source of the income. In cases where income has multiple sources, the dominant factor or factors must be determined. If necessary, the income must be apportioned among the various sources.

The source of income for tax purposes is determined according to the law of the country seeking to tax the recipient. Thus, while payments made by an Australian company for US ''know-how’’ supplied in the US under a contract made in the US would probably have a US source according to generally accepted concepts of source, they are specifically deemed, for Australian tax purposes, to have an Australian source.

If you would like more information on any aspect of international taxation, contact our office on 9460 5000.

International Taxation Links:

International Inland Revenue UK
www.inlandrevenue.gov.uk/home.htm

Internal Revenue Service - USA 
www.irs.gov

Singapore Revenue Authority 
www.iras.gov.sg

Inland Revenue Department Hong Kong
www.info.gov.hk/ird

Canada Customs and Revenue Agency
www.ccra-adrc.gc.ca/menu-e.html

Inland Revenue New Zealand
www.ird.govt.nz/menu.htm