Meaning of tainted services income



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End of attention

Tainted services income, in broad terms, means income derived from the provision of services by a company to:

  • a resident (except in connection with a foreign permanent establishment of the Australian resident), or
  • a non-resident in connection with the non-resident's Australian permanent establishment.

Tainted services income also includes income derived from services provided indirectly to Australian residents, subject to certain requirements.

Services includes any benefit, right or privilege provided under an arrangement for the performance of work or the provision of facilities - for example, performance of technical, managerial or transport work.

Tainted services income

Provided to

Tainted services?

Associated Australian


Associated non-resident (via Australian branch)


Unassociated Australian


Associated non-resident (not via Australian branch)

No, subject to indirect services rule

Unassociated non-resident (via Australian branch)


Unassociated non-resident (not via Australian branch)


Last modified: 05 Dec 2006QC 18000