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Edited version of private advice
Authorisation Number: 1052236101874
Date of advice: 9 May 2024
Ruling
Subject: Foreign employment income - double tax agreement
Question
Is the employment remuneration you receive from your overseas employer exempt from tax in Australia pursuant to Article X of the Convention between the Government of Australia and the Government of Country A which deals with governmental functions?
Answer
Yes.
This ruling applies for the following periods:
Year ended 30 June 20XX
The scheme commenced on:
XX XXX 20XX
Relevant facts and circumstances
You are a citizen of Country A.
You are a permanent resident of Australia.
You are an Australian resident for tax purposes.
You are employed overseas in Country A as a government employee.
You perform this role remotely from Australia.
You receive a salary from your overseas employer which is taxed in Country A.
An overview of your duties and responsibilities in this role was provided.
Relevant legislative provision
Income Tax Assessment Act 1997 section 6-5
Income Tax Assessment Act 1997 section 6-20