Private ruling: Foreign employment income - double tax agreement
Date of advice: 9 May 2024
Published: 17 June 2024
Ruling period: Year ended 30 June 20XX
Date scheme commenced: XX XXX 20XX

Ruling: Q1: 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? | A1: Yes.

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