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Edited version of private advice
Authorisation Number: 1051606127116
Date of advice: 19 November 2019
Ruling
Subject: Assessability of Australian sourced income
Question
Is the income you earned in Australia as a short term contractor assessable income in Australia?
Answer
No. You are a non-resident performing independent personal services in Australia, you are in Australia for less than 183 days and do not have a fixed base available to you.
This ruling applies for the following period:
Year ended 30 June 2019
The scheme commences on:
1 July 2018
Relevant facts and circumstances
You are a citizen and resident of Country A, who arrived and departed Australia in late 2018.
You spent a total of XX days in Australia in the 2018-19 income year.
When working as a short term contractor in Australia, you were represented by Company A.
You attended a show as a contractor under contract with a local campaign.
During your time in Australia you earned $XX in gross revenue.
You have provided the following documents:
· A copy of the contract of agreement between yourself and Company A.
· Copies of the Booking confirmations with Australian customer(s).
· PAYG summary.
· A copy of your passport.
· A statement of your local bank account.
No fixed based was available to you during your time in Australia.
Relevant legislative provisions
Income Tax Assessment Act 1997 Subsection 6-5(3)
International Tax Agreements Act 1953 Article 4
International Tax Agreements Act 1953 Article 5
International Tax Agreements Act 1953 Article 14