The ATO has in recent years taken an expansive approach on whether a person resides in Australia for tax purposes. The effect has been that many taxpayers, who assumed they had safely left their tax residency behind, continue to be taxed in Australia on their worldwide income. Disputes are becoming more common as a result of the ATO's increased datamatching capabilities.
Some of Dempsey litigation is covered including:
- the ordinary meaning of "resides'
- the concepts of domicile and permanent place of abode
- when the tie-breaker tests in the double tax agreement apply
- common risk areas - and how you can help your clients deal with them
- strategies for preventing - or managing - disputes with the ATO.