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Edited version of private advice
Authorisation Number: 1051966348639
Date of advice: 31 March 2022
Ruling
Subject: Residency
Question
Are you a resident trust for the specified income years?
Answer
Yes. As the trustee of the Trust is a company incorporated in Australia you will be a resident trust for the specified income years.
This ruling applies for the following periods:
Year ending 30 June 20XX
Year ending 30 June 20XX
The scheme commences on:
1 July 20XX
Relevant facts and circumstances
The Trustee of the Trust is Company A.
Company A was incorporated in Australia on a specified date.
The sole director of Company A is Person A who is an Australian resident for tax purposes.
Your business has been conducted remotely from Country A since a specified date.
All your business income is paid in Australian dollars and paid into an Australian bank account.
You have mostly Australian clients with the exception of one international client that is based in Country B that has a head office located in Australia.
You do not have any clients located in Country A.
Relevant legislative provisions
Income Tax Assessment Act 1997 section 995-1