Private ruling: Assessable income - foreign sourced income
Date of advice: 29 January 2026
Published: 23 March 2026
Ruling period: Year ended 30 June 20YY | Year ending 30 June 20YY | Year ending 30 June 20YY | Year ending 30 June 20YY | Year ending 30 June 20YY
Date scheme commenced: 1 July 20YY

Ruling: Q1: Will the Commissioner allow you to report your Country X foreign sourced income on a Country X income year basis in your Australian income tax return? | A1: Yes. Taxation Ruling IT 2498 Income Tax: foreign tax credit system: currency translation of foreign income: trading stock and depreciable plant: basis of returning foreign income: capital gains/losses, addresses the issue of foreign income and expenses to be reported for an Australian income year where foreign accounts and/or tax apply on a different basis. Paragraph 39 of IT 2498 provides that individual taxpayers who are required to prepare foreign source income accounts on a basis other than a year ending 30 June and who can demonstrate difficulties in dissecting the income/expenses for the purposes of returning on a strict Australian income year basis in relation to a year of income, may be permitted to report the foreign source income in their Australian return for that year of income on the relevant foreign income year basis. In your case, you are in receipt of foreign income sourced from Country The Country X income year ends on DD MM. As a result of regulatory and reporting requirements imposed by the relevant foreign tax authorities, you face significant difficulty in obtaining information in relation to the foreign income within a suitable timeframe to include in your Australian tax return by the due date. The Commissioner accepts that your circumstances are consistent with those outlined in IT 2498 and will allow you to report the foreign sourced income on a Country X income year basis in your Australian tax return.

Relevant facts and circumstances: You are a resident of Australia for taxation purposes. Your tax returns are prepared by a tax agent. You derive a portion of your income from Country X. Your tax agent has difficulty obtaining information relating to your Country X foreign income in a timely manner to prepare your Australian tax returns by the due date. This is due to the information not being available because of regulatory and reporting requirements imposed by the relevant foreign authorities. The Country X income year ends DD MM. Your tax agents in Country X require time to report information for the Country X income year. Due to lodgement extensions in Country X, your Country X tax returns may not be finalised for some time. Once your returns are finalised in Country X, they are provided to your Australian tax agent to process.

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