Residency

We focus on individuals, companies and trusts shifting their tax residency to another jurisdiction before or during restructures or asset disposals within their family group with the aim of:

• avoiding an Australian tax liability
• obtaining tax benefits on the disposal of CGT assets
• making tax-free distributions to associates.

Other situations that attract our attention include when tax has not been paid on:

• an entity's assets when ceasing to be an Australian resident
• a resident entity's worldwide income.

We also focus on wealthy individuals who change their Australian residency status commensurate with a significant income event occurring in their personal lives or in relation to their family group.

There is more information about central management and control test in the below resources:

• TR 2018/5 Income tax: central management and control test of residency
• PCG 2018/9 Central management and control test of residency: identifying where a company's central management and control is located.

For assistance with residency status, see Working out your residency.