Personal services income: the current landscape
Published Date: 13 Oct 2025
The personal services income rules have been in force since the Ralph report with little change. However, recent ATO guidance that considers the interaction between Pt IVA and the personal services income rules, as well as further revisions to the ATO’s views on the allocation of profits for professional practices, create some uncertainty as to how these rules operate. This article reviews the personal services income rules and the evolution of key case law. The article also covers the recent ATO guidance and how it may apply to taxpayers in a practical sense. The author then considers whether the ATO guidance is in line with current case law, or if further case law is needed to clarify the Commissioner’s position, especially in respect of the Pt IVA/personal services income interaction.
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- Published By: Ben Macpherson
- Published On:13 Oct 2025
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