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  • International taxation


    International taxation chapter


    International taxation detailed tables


    Taxation statistics - whole document


    This chapter provides information on the international dealings of Australian residents as reported on individual, company, partnership, trust and super fund tax returns. Australian residents are generally taxed on their worldwide income whereas non-residents are generally taxed only on their Australian-sourced income (and some specific amounts not dependent on source).

    The residency tests the ATO uses to determine residency status for income tax purposes are not the same as those used by other Australian agencies.

    Generally, individuals are resident of Australia for tax purposes if they 'reside' here under ordinary concepts. Individuals may also be treated as residents in certain circumstances. This happens if they have an Australian domicile, unless their permanent home is outside Australia, or if they have actually been in Australia for more than half the income year, unless their usual home is overseas and they do not intend to live in Australia. A member of a Commonwealth superannuation fund, or spouse or child of that person, may also be treated as a resident for tax purposes.

    A company is a resident of Australia for tax purposes if:

    • it is incorporated in Australia, or
    • not incorporated in Australia but carries on business in Australia and has either:
      • its central management and control in Australia, or
      • its voting power controlled by Australian resident shareholders.

    Partnership and trust returns are completed on the assumption of residence, but non-resident partners or beneficiaries are generally only taxed on their interest in Australian sourced income (and some specific amounts not dependent on source).

    Superannuation fund returns are prepared under the assumption of residence, except for a non-complying fund that is a foreign superannuation fund in which case the trustee is assumed to be a non-resident.


    For the 2008-09 income year:

    • 955,562 individuals lodged returns with foreign sourced income, a 10.7% decrease from 2007-08
    • individual foreign sourced income was $3.1 billion, an increase of 1.2% from 2007-08
    • corporate net foreign sourced income was $10 billion, a decrease of 2.4% from 2007-08
    • super funds net foreign sourced income was $5.4 billion, a decrease of 42.3% from 2007-08.
      Last modified: 18 Oct 2011QC 23907