Private ruling: Assessable income
Date of advice: 16 March 2026
Published: 29 June 2026
Ruling period: Year ending 30 June 2027 | Year ending 30 June 2028 | Year ending 30 June 2029 | Year ending 30 June 2030
Date scheme commenced: 1 July 2026

Ruling: Q1: Is income earned as a locally engaged staff member at the Country Z Consulate assessable in Australia? | A1: No Article X of Country Z's tax treaty is applicable and its effect is to exempt your LES income in Australia.

Relevant facts and circumstances: You were hired by the Country Z Consulate General several years ago as a locally engaged staff (LES) member You are a LES working at the Country Z Consulate General performing governmental functions in Australia within the meaning of the relevant Article of the Double Tax Convention between Australia and Country Z (the Convention). You are a citizen of Country Z. You are a citizen of Australia. You are a resident of Australia for taxation purposes. You are not a resident of Country Z for taxation purposes. You moved to Australia and have resided in Australia for several years You became an Australian citizen in a few years ago. You are not a diplomat or a Foreign Service officer. You maintain your permanent home in Australia.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 6-5