ato logo
Search Suggestion:


We review tax residency changes relating to restructures, asset disposals or a significant increase in worldwide income.

Last updated 23 August 2022

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.