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