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This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law.

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Edited version of your written advice

Authorisation Number: 1051352338850

Date of advice: 27 March 2018

Ruling

Subject: Residency - departed

Question 1

Are you a resident of Australia for income taxation purposes from the day you departed Australia?

Answer 1

Yes

Question 2

Will your income from your overseas country B employer be assessable income in Australia?

Answer 2

Yes

Question 3

Will your income from your overseas country C employer be assessable income in Australia?

Answer 3

Yes

This ruling applies for the following periods:

Year ended 30 June 2016

Year ended 30 June 2017

Year ended 30 June 2018

Year ended 30 June 2019

The scheme commences on:

1 July 2015

Relevant facts and circumstances

You are a dual citizen of overseas country A and Australia

You arrived in Australia from country A

You became an Australian citizen later

You were made redundant from your employment

For various reasons you moved to overseas country B to work

You have been working for an entity in overseas country B on an open contract which will be terminated

You have been fully taxed on your overseas salary in country B

Upon your arrival in overseas country B you stayed in temporary accommodation for a short period

You then moved to other temporary accommodation for a short time in overseas country B

You then lived in a shared privately rented premises in overseas country B for a longer period of time

You moved back into temporary accommodation and will depart overseas country B soon

You had overseas country B medical insurance

You took your personal effects with you upon departure and your old personal effects were given or thrown away

You have an overseas country B bank account and credit card which you will close

Living in overseas country B has allowed you to be closer to the overseas country A where you have family

You also have a child who lives in overseas country A

You intend on eventually returning to overseas country A to look after and be closer to your family members there

You may use overseas country B as a family base in the future

You have recently accepted a new job working for an entity in overseas country C

You will not pay tax on your salary in overseas country C

You will commence work in overseas country C the future pending a visa

Your salary will be paid into a local bank account in overseas country C, which you will open when you commence work

You purchased a vehicle in overseas country B which you will take to overseas country C

You will obtain an overseas country C medical card

Your long-term plan is to work in overseas country C for a number of years

The overseas country C entity will provide family accommodation at a cost

You advised that moving your family to overseas country C does not appear to be a realistic option for you due to the following considerations: the security situation, the lower educational school standards, the lack of employment for your spouse, the isolation and extreme climatic and cultural conditions

You have advised another option of moving your family to overseas country D, a long travelling distance away is also not appropriate for you

Upon your departure from Australia your spouse and child remained in the family home you own with your spouse in Australia

Your spouse is employed in Australia and your child attends school in Australia

You have a shared bank account with your spouse which you have set-up long-term direct debit payments to pay for the Australian household expenses such as electricity, water, gas, phone, internet and other costs using from this account

Your spouse uses a motor vehicle registered in your name

Your Australian house is furnished with white goods and furniture

When you go to overseas country C you will ask your spouse to register the motor vehicle in her name and change the bank account into her name only

During your time in overseas country B you repatriated about half of your salary every month after your living expenses

It is likely you will be made redundant soon and you will repatriate the fully taxed funds to Australia

When you go to overseas country C you plan on returning all of your salary to your spouse and child after your monthly living and travel costs have been removed

Whilst you are working in overseas country C you plan to meet your spouse and daughter in another overseas location to have a holiday

You will arrange meet ups with your family who are in Australia in overseas country A

You have no plans at this stage to return to Australia permanently. You have said it is difficult to plan ahead

You do not plan on returning to Australia very often, unless it is necessary

You removed your name from the Australian Electoral Register when you departed Australia

You have no investments, shares or investment properties in Australia or in overseas country A

You closed your interest generating bank accounts a time after you departed Australia

You now do not receive any income from Australian sources

You have not put any money into your superannuation since leaving Australia

You have a overseas country A bank account which you have had for a long time and is used for pension payments

You have a driving licence for overseas country B and you will obtain a overseas country C driver’s license

You will allow your Australian driver’s licence to lapse

You are considering allowing your Australian passport to lapse

Since your departure you have visited Australia for short infrequent visits

You have discontinued using your Australian Medicare card

You advise in the future you are unlikely to obtain an Australian government pension or Centrelink payments as you will receive a pension at age 66 from overseas country A

You and your spouse have never been employed by the Commonwealth of Australia

You are not a member of the Public Sector Superannuation Scheme

Relevant legislative provisions

Income Tax Assessment Act 1936 section 6(1)

Income Tax Assessment Act 1997 section 6-5

Income Tax Assessment Act 1997 section 995-1

Reasons for decision

The terms resident and resident of Australia, in regard to an individual, are defined in subsection 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936).

The definition offers four tests to ascertain whether each individual taxpayer is a resident of Australia for income tax purposes. These tests are the:

If any one of these tests is met, an individual will be a resident of Australia for taxation purposes.

The primary test for deciding the residency status of each individual is whether they reside in Australia according to the ordinary meaning of the word resides. Where an individual does not reside in Australia according to ordinary concepts, they may still be considered to be an Australian resident if they meet the conditions of one of the other tests.

Relevant to your situation are the first two tests which are examined in detail in Taxation Ruling IT 2650 Income Tax: Residency - permanent place of abode outside Australia (IT 2650). In examining these tests, IT 2650 provides a number of factors which assist in assessing a taxpayer’s situation against the tests. A copy of this ruling is available from www.ato.gov.au.

The resides (ordinary concepts) test

The resides test considers whether an individual is residing in Australia according to the ordinary meaning of the word ‘reside’. As the word ‘reside’ is not defined in Australian taxation law, it takes its ordinary meaning for the purposes of subsection 6(1) of the ITAA 1936.

The ordinary meaning of the word 'reside', according to the Macquarie Dictionary, 2001, rev. 3rd edition, The Macquarie Library Pty Ltd, NSW, is 'to dwell permanently or for a considerable time; having one's abode for a time', and according to the Compact Edition of the Oxford English Dictionary (1987), is 'to dwell permanently, or for a considerable time, to have one's settled or usual abode, to live in or at a particular place'.

In Dempsey and Commissioner of Taxation [2014] AATA 335 (Dempsey), the Administrative Appeals Tribunal of Australia (AATA) restated that the cases of Levene v Inland Revenue Commissioners [1928] AC 217, Lysaght v Inland Revenue Commissioners [1928] 13 TC 511 and Federal Commissioner of Taxation v Miller [1946] 73 CLR 93 were authoritative on the meaning of the word ‘resides’.

The question of whether an individual ‘resides’ in a particular country is a question of fact and degree and not of law. In deciding this question, the courts have consistently referred to and taken into account the following factors as being relevant:

The weight given to each factor varies with individual circumstances and no single factor is necessarily decisive. In Shand v Federal Commissioner of Taxation [2003] ATC 2080, the Tribunal stated:

Generally the Commissioner considers that it is difficult for a taxpayer to demonstrate that they have ceased to be a resident of Australia where a place of residence remains available to them in Australia and/or where their spouse remains living in Australia. In these situations, it may be considered that the taxpayer meets the resides test as they have retained a continuity of association with Australia. Further, they may also meet the domicile test as the Commissioner may not be satisfied that they have a permanent place of abode outside Australia. Examples of decisions of this type can be found in Iyengar and Federal Commissioner of Taxation [2011] AATA 856 and Sneddon and Commissioner of Taxation [2012] AATA 516.

In the case of Shord and Federal Commissioner of Taxation [2015] ATC 355 (Shord) one of the factors leading to the conclusion that the taxpayer was a resident of Australia was the taxpayer’s emotional connection to his spouse who resided in their house in Western Australia. It was considered that the taxpayer maintained a continuity of association with Australia mainly through his spouse and property in Australia.

Examples of different outcomes can be found in two recent cases, The Engineering Manager and Commissioner of Taxation [2014] AATA 969 (Engineering Manager) and Dempsey. In both of these cases, the taxpayers left Australia to work overseas and were found to be non-residents, as in the opinion of the AATA, they did not meet the resides or domicile tests of residency.

In Dempsey, the taxpayer was found to be a non-resident even though he maintained a place of residence containing his household effects and vehicles in Australia. He also stayed at the house on his occasional return visits to Australia. In this case, the taxpayer was not in a relationship and had adult children living in Australia. The AATA noted that he was a ‘free agent’ not only in terms of the transferability of his skills, but also in terms of his ‘personal circumstances’. That is, he was a single man who left no family at the house.

In the Engineering Manager, the taxpayer was found to be a non-resident even though he maintained a place of residence in Australia in which his spouse and children lived. The AAT stated that his connection with his children was not determinative of whether he resided in Australia. The AATA also stated that his marital relationship was ‘fractured’ and that the inharmonious nature of the relationship was considered to be a ‘very significant factor’ (in finding that he was a non-resident).

Your circumstances are ultimately different to Dempsey as the taxpayer did not have his spouse or family living in his dwelling and it is also different from the Engineering Manager as there is nothing to indicate that you had or will have an inharmonious relationship with your spouse during the relevant period.

As noted above, to determine whether or not you are residing in Australia for taxation purposes, it is necessary for us to examine a number of factors in the context of your circumstances.

In your case, there are various factors that indicate that you may have been residing outside Australia during the relevant period, as follows:

However, there are also various factors that indicate that you may have still been residing in Australia, as follows:

We consider that your circumstances are more closely aligned with Iyengar, where the taxpayer was found to be a resident, despite living and working overseas for greater than a two year period. The AATA stated that the taxpayer retained a ‘continuity of association’ with Australia during the relevant income years, which included the following:

In your case, we consider it significant that your spouse and child did not join you in overseas country B and will not be joining you in overseas country C. Your spouse and child decided not to join you as your spouse is employed in Australia and your child is engaged in schooling in Australia, of which they could not pursue in overseas country C. You also advised that the security situation in overseas country C, lower educational school standards, lack of employment, isolation and extreme climatic and cultural conditions were your considerations for your spouse and child remaining in Australia.

Whilst we recognise that these factors have led to the decision for your spouse and child to not join you overseas country C, they are not situations that could be considered as unusual or out of the ordinary, nor are they unforeseen circumstances. The fact remains that your family remain living in your dwelling which remains available for your use during the time you are overseas.

You had economic ties to overseas country B by way of your employment a bank account and your bike. You will have economic ties to overseas country C by way of your employment and a bank account. You have also taken some personal belongings and effects with you.

However your ties to Australia which include your family, along with your furnished home, in which your family live in whilst you are in overseas country B and soon to be overseas country C and is available to you whilst you are overseas are stronger. You have economic ties to Australia by the way of your property, bank account and motor vehicle. You have sent and will be sending funds sourced from your income earned in overseas country B and overseas country C to an Australian bank account to financially support your family. You travelled to Australia to see your family for short infrequent visits.

Consequently, we consider that, on balance, your intention to work overseas for a considerable and indeterminable time is outweighed by the continuity of association you retain with Australia.

Based on these facts, you are residing in Australia according to the ordinary meaning of the word. Therefore, you meet the ‘resides test’ and are a resident of Australia for tax purposes.

Whilst it is not necessary to meet more than one test to determine residency for tax purposes (we have already established that you are a resident under the ‘resides’ test), we will also include a discussion of the ‘domicile and permanent place of abode’ test as an alternative argument.

The domicile test

Under this test, a person is a resident of Australia for tax purposes if their domicile is in Australia, unless the Commissioner is satisfied that their permanent place of abode is outside of Australia.

Domicile

Domicile is a legal concept, determined according to the Domicile Act 1982 and common law rules established by private international law cases.

A person's domicile is generally their country of birth. This is known as a person's 'domicile of origin'. A person may acquire a domicile of choice in another country or acquire another domicile by operation of law.

In order to show that a new domicile of choice in a country outside Australia has been adopted, the person must be able prove an intention to make his or her home indefinitely in that country. The intention needs to be demonstrated in a legal sense, for example, by way of obtaining a migration visa, becoming a permanent resident or becoming a citizen of the country concerned.

In this regard paragraph 21 of IT 2650 states that:

In your case, you were born in overseas country A and therefore your domicile of origin is overseas country A. You have lived in Australia and then you became a citizen. You established a permanent home in Australia. You maintain ownership of your property in Australia, where your family lives. You will be transferring some of your overseas earnings to your family in Australia. Your higher value assets are located in Australia.

As domicile is a legal concept in which an intention to establish a permanent home is made, the Commissioner is satisfied that at the latest, you acquired a new domicile of choice in Australia in 2009. Being when you acquired your citizenship which permitted you to remain in Australia indefinitely. To be eligible to obtain Australian citizenship you are required to have intended to live or maintain a close and continuing association with Australia (further information available at www.border.gov.au).

In Shord the taxpayer was born in the United Kingdom. He started living in Australia in 1978 and he became a citizen in 2004. He worked overseas on offshore vessels. It was held that his domicile would not revert to his domicile of origin upon the taxpayer forming an intention to abandon Australia as a domicile of choice as the taxpayer had not proven that he had acquired another domicile. In this case the taxpayer did not have a permanent place of abode outside of Australia.

You have not reverted to your domicile of origin as there has been no evidence to demonstrate that you intend to make your permanent home in overseas country A.

You have not obtained a new domicile of choice of overseas country B as you have not, and will not be taking any legal steps such as becoming a permanent resident or a citizen of overseas country B.

You will not obtain a new domicile of choice of overseas country C as you have not indicated that you will be taking any legal steps, such as obtaining a migration visa, becoming a permanent resident or a citizen of overseas country C, which would prove an intention to change your domicile to overseas country C, therefore you have retained your Australian domicile. You are obtaining a visa in overseas country C which allows you to live and work in overseas country C. We still consider your domicile to be in Australia as the visa is required to be renewed and is not sufficient evidence to acquire a domicile of choice other than Australia.

Therefore, you will be a resident of Australia unless the Commissioner considers you have established a permanent place of abode outside of Australia.

Permanent place of abode

It is clear from the case law that a person’s permanent place of abode cannot be ascertained by the application of any hard and fast rules. It is a question of fact to be determined in the light of all the circumstances of each case.

The courts have considered a person’s ‘place of abode’ is where they consider ‘home’. In R v Hammond [1982] ER 1477, Lord Campbell CJ stated that “a man’s residence, where he lives with his family and sleeps at night, is always his place of abode in the full sense of that expression.”

The Full Court of the Federal Court concluded in the first place that the 'domicile and permanent place of abode test' is not concerned with whether a person has abandoned his or her Australian domicile or has acquired a new domicile or not; what is of importance is whether the taxpayer has abandoned any residence or place of abode he or she may have had in Australia.

The decisions in Shand and lyengar establish that a taxpayer's long absence from Australia does not automatically lead to his or her divestment of Australian residency unless it can be established that the taxpayer has set up a 'permanent place of abode', outside Australia.

In each of the above cases the court found that the overseas accommodations of the taxpayers lacked the characteristics of a 'permanent place of abode' in relation to the nature and quality of the use of the accommodations by the taxpayers. Further, the taxpayers not only maintained a place of residence in Australia but also retained a continuity of association with Australia, together with an intention to return to Australia.

That the taxpayers retained a continuity of association with Australia was evidenced by their visits to their family home in Australia whenever their business or work commitments allowed. The wives and children of the taxpayers continued to live in Australia and did not join the taxpayers at their overseas abode, except for three short visits by the family in the case of Iyengar. Additionally, the taxpayers retained substantial personal property items in Australia and, in Iyengar, the taxpayer's cars.

This led to the conclusion that the overseas accommodations of the taxpayers were no more than temporary or transitory places of abode and distinguishable from a 'permanent place of abode' as exemplified in Applegate.

In contrast, the AATA found the taxpayer in Federal Commissioner of Taxation v Mynott [2011] ATC 10-195; AATA 539 (Mynott) to be a non-resident and although he spent a third of the period under consideration in Australia, it was held that his factual circumstances and what took place in Australia when he left Australia were not significantly different to the circumstances presented in Applegate. He had sold his substantial assets and his principal residence in Australia. However, he kept a room at his parent's house in Australia, retained small investments, disclosed his parent's residential address in relation to his taxation returns and investments and kept his name on the Australian electoral roll.

Of significance is the fact that he had established a home in the Philippines where his partner and children lived. He worked overseas as he was unable to secure work in the Philippines. His overseas earnings, although deposited in an Australian bank account, were transferred to the Philippines for the living and schooling expenses of his family. He visited his parents in Australia on the completion of a contract, however, he would always return to the Philippines to be with his family.

Ultimately, the nature and quality of the use that the taxpayer made of his apartment in the Philippines was seen by the court as the establishment of a 'permanent place of abode' in the Philippines.

The Commissioner’s view on what constitutes a permanent place of abode is contained in IT 2650.

Paragraph 23 IT 2650 sets out the following factors which are used by the Commissioner in reaching a state of satisfaction as to a taxpayer's permanent place of abode:

In relation to the weight to be given to each of the above factors, paragraph 24 of IT 2650 states:

In your case it is considered that you have not established a permanent place of abode outside of Australia because:

Although you intend on living and working in overseas country C for a considerable and indeterminable time and you will take some personal belongings with you will not abandon your residence in Australia. Your Australian residence is still available to you, and you have retained a durable association with Australia, in particular through your family who remain in Australia.

Consequently, the Commissioner is not satisfied that you have a permanent place of abode outside Australia, and you are therefore a resident under the domicile test of residency during the period you will work in overseas country B and overseas country C.

Your residency status

As you meet the resides and domicile tests of residency, you are a resident of Australia for income tax purposes under section 6(1) of the ITAA 1936.

Question 2

Section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997) provides that where you are a resident of Australia for taxation purposes, your assessable income includes income gained from all sources, whether in or out of Australia. However, where you are a foreign resident, your assessable income includes only income derived from an Australian source.

Foreign Income - Double Tax Agreements

Australia has double tax agreements (DTAs) with more than 40 countries worldwide. The main purpose of double tax agreements is to avoid double taxation as well as to prevent taxation evasion. In addition, these agreements often settle differences of interpretation and provide a system for consultation and resolution of disputes between the tax administrations of Australia and another country.

In determining liability to tax on foreign sourced income received by an Australian resident taxpayer it is necessary to consider not only the income tax laws but also any applicable tax treaty contained in the International Tax Agreements Act 1953 (Agreements Act). If there is no relevant tax treaty, the income will be taxed according to Australian income tax laws.

Section 4 of the Agreements Act incorporates that Act with the ITAA 1936 and the ITAA 1997 so that all three Acts are read as one. The Agreements Act overrides both the ITAA 1936 and ITAA 1997 where there are inconsistent provisions (except in some limited situations).

Section 5 of the Agreements Act states that, subject to the provisions of the Agreements Act, any provision in an Agreement listed in section 5 has the force of law. The overseas country B Agreement is listed in section 5 of the Agreements Act.

The overseas country B agreement is located on the Austlii website (http://www.austlii.edu.au/) in the Australian Treaties Series database. The overseas country B Agreement operates to avoid the double taxation of income received by residents of Australia and overseas country B.

Article 4(2) of the overseas country B Agreement provides tests of residency that are used where the individual is a resident of the two countries (tie breaker tests). The tie breaker tests ensure that the individual is a resident of one country for the purposes of working out liability to tax on their income. The tie breaker rules do not change a taxpayer’s residency status for domestic law purposes.

As you are an Australian resident for income tax purposes and overseas country B also considers you a resident for tax purposes, it is necessary to consider the tie breaker rules in the overseas country B Agreement.

Article 4(2) of the overseas country B Agreement describes how a person’s residency status for the purpose of applying the overseas country B Agreement shall be determined.

Permanent home

To assist in the interpretation of the overseas country B Agreement, reference is made to Taxation Ruling TR 2001/13 - Income tax: Interpreting Australia's Double Tax Agreements (TR 2001/13).

Paragraph 104 of TR 2001/13 states that the OECD Model Tax Convention and Commentary (OECD Commentary) will often need to be considered in interpreting tax treaties.

The OECD Commentary provides that in relation to a 'permanent home':

In your case, you had a permanent home available to you in both Australia and overseas country B. In Australia you have a home readily available to you, being the family home. In overseas country B you lived in longer term rental accommodation that was available for your use.

Personal and economic ties

The centre of vital interests test is relevant only where a taxpayer has a permanent home available in both Australia and the overseas country B, or does not have a permanent home available in either Australia or overseas country B.

The question of where a taxpayer’s personal and economic relations are closest differs from the question that arises with respect to residency under domestic law. It is necessary to determine which set of personal and economic relations are the closest.

Para 15 of the OECD Commentary on Article 4(2)(a) states:

Klaus Vogel on Double Taxation Conventions, Third Edition, Kluwer Law International 1997, is consistent with paragraph 15 of the OECD Commentary on Article 4(2)(a) and states that 'personal relations encompass a taxpayer's entire way of life'. This includes family and social, political and cultural relations.

In Tan v FCT [2016] AATA1062 CR Walsh SM states:

In your case, your family lives in Australia. You continued to provide financial support to your family in Australia. You owned a car in Australia and maintained an Australian driver’s licence. You maintained ownership of your dwelling in Australia. You maintained a joint Australian bank account. You are an Australian citizen and your domicile is Australian. You have superannuation funds in Australia. Your ties to overseas country B include your employment, bank account, driver’s licence, rented apartment, and bike.

Your vital interests are circumstances in your everyday life that not only reflect your day-to-day needs but also your longer-lasting ties. Your family and economic ties to Australia are more significant than those to overseas country B. Accordingly as you have closer economic and personal relations to Australia, under paragraph (a) of Article 4(2) of the overseas country B Agreement, you are a resident of Australia for the purposes of applying the provisions of the overseas country B Agreement to income earned by you whilst in overseas country B.

Salary and wages

Article 14(1) of the overseas country B Agreement advises that salaries, wages and other similar remuneration derived by a resident of Australia shall be taxable only in Australia unless the employment is exercised in overseas country B. If the employment is exercised in overseas country B then the income may also be taxed in overseas country B.

However, Article 14(2) lists the circumstances where remuneration derived by an individual who is a resident of Australia in respect of an employment exercised in overseas country B shall be taxable only in Australia.

As you were present in overseas country B for more than 183 days in a 12 month period, your employment income will not be solely assessable in Australia.

As an Australian resident for the purposes of the overseas country B Agreement, Australia has the primary taxing right over your remuneration from overseas country B. However, you are entitled to a foreign income tax offset in Australia in relation to any tax paid in overseas country B.

Foreign Income Tax Offset

Subsection 770-10(1) of the ITAA 1997 provides for a foreign income tax offset (FITO) for an income tax year for foreign income tax paid in respect of an amount that is included in assessable income.

Section 770-15 of the ITAA 1997 defines 'foreign income tax' to include a tax on income that is imposed by a law other than an Australian law. A note to section 770-15 of the ITAA 1997 points out that 'foreign income tax' includes only that which has been correctly imposed under the foreign law, and where the foreign jurisdiction has a tax treaty with Australia under the Agreements Act, foreign income tax includes only tax which has been correctly imposed under the treaty.

If you have assessable income from overseas, you must declare it in your Australian income tax return. If you have paid foreign tax in another country, you may be entitled to an Australian foreign income tax offset (FITO), which provides relief from double taxation.

The FITO rules apply for income years that start on or after 1 July 2008. Different rules apply for income periods up to 30 June 2008.

To qualify for a FITO you must meet all of the following criteria:

The FITO is a non-refundable tax offset. The FITO is applied to your income tax liability including the Medicare levy and the Medicare levy surcharge where applicable. Any excess is not refunded to you.

If you are claiming an offset of $1,000 or less, you only need to record the actual amount of foreign income tax paid on your assessable income (up to $1,000).

If you are claiming a FITO of more than $1,000, you will first need to work out your FITO limit. The FITO that can be claimed is limited to the lesser of foreign income tax paid and the FITO limit.

The limit is the amount of Australian income tax payable on that foreign income. The Medicare levy and the Medicare levy surcharge are included in calculating the FITO.

The difference between the foreign income tax paid and the FITO limit cannot be refunded or carried over to a future income year.

Question 3

As you are a resident of Australia for income tax purposes under subsection 6(1) of the ITAA 1936, the income from your contract of employment in overseas country C is taxable within section 6-5(2) of the ITAA 1997.

In this case overseas country C does not currently have a tax treaty with Australia and therefore the assessability of the income you receive from overseas country C is determined on the basis of Australian income tax law.

Therefore as noted above the income from your contract of employment to be performed in overseas country C is taxable in Australia.

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