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Edited version of private advice
Authorisation Number: 1051848883591
Date of advice: 10 June 2021
Ruling
Subject: Taxation of employment income
Question
Is your employment income from Private Organisation X assessable in Australia from the time you were no longer an Australian resident?
Answer
No. Based on the information provided to the Commissioner, the income you derive from your employment with Private Organisation X is not assessable in Australia.
Article X of the relevant Double Taxation Agreement deals with employment income and gives Country X the sole taxing rights on the income derived from the employment with Private Organisation X.
This ruling applies for the following period:
Year ending 30 June 20XX
The scheme commences on:
1 July 20XX
Relevant facts and circumstances
You commenced work with Private Organisation X in early 20XX in Australia.
In Season 20XX you and your family moved to Country X on a permanent basis.
You are no longer a resident of Australia for taxation purposes.
You remain employed by Private Organisation X on a full-time basis in Australia.
You work remotely for Private Organisation from Country X
Your focus is on Australian business's and marketing to Australian clients.
Relevant legislative provisions
Income Tax Assessment Act 1997 section 6-5