Private ruling: Taxation of employment income
Date of advice: 10 June 2021
Published: August 2021
Ruling period: Year ending 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Is your employment income from Private Organisation X assessable in Australia from the time you were no longer an Australian resident? | A1: No. Based on the information provided to the Commissioner, the income you derive from your employment with Private Organisation X is not assessable in Australia. Article X of the relevant Double Taxation Agreement deals with employment income and gives Country X the sole taxing rights on the income derived from the employment with Private Organisation X.

Relevant facts and circumstances: You commenced work with Private Organisation X in early 20XX in Australia. In Season 20XX you and your family moved to Country X on a permanent basis. You are no longer a resident of Australia for taxation purposes. You remain employed by Private Organisation X on a full-time basis in Australia. You work remotely for Private Organisation from Country X Your focus is on Australian business's and marketing to Australian clients.

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


This ruling applies for the following period: