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Corporate Tax Residency Review


In August 2019 the Treasurer wrote to the Board of Taxation asking the Board to conduct a review of the operation of Australia’s corporate tax residency rules. The purpose of the review is to ensure that the rules are operating appropriately in light of modern, international and commercial board practices and international tax integrity rules.

Terms of Reference

The terms of reference set out by the Treasurer are for the Board to consider whether the existing rules:

Working Group

The Board has appointed Board member Neville Mitchell to lead the work on this review. Mr Mitchell is assisted by fellow Board members Dr Julianne Jaques and Mrs Ann-Maree Wolff. Representatives from academia, industry and the tax profession will also be assisting in the review.

Initial Consultation

The Board has prepared a consultation paper in order to initiate the first part of its review. The consultation paper sets out some observations on the current corporate residency rules, and poses a number of questions about the ongoing viability of these rules for stakeholder consideration.

The Board seeks your input via the following consultation options:

Further Information

Please contact the Board of Taxation Secretariat at or +61 2 6263 4366 for more information.

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