Private ruling: Assessability of Australian sourced income
Date of advice: 19 November 2019
Published: February 2020
Ruling period: Year ended 30 June 2019
Date scheme commenced: 1 July 2018

Ruling: Q1: Is the income you earned in Australia as a short term contractor assessable income in Australia? | A1: 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.

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