Private ruling: International Income
Date of advice: 12 December 2018
Published: April 2019
Ruling period: Year ended 30 June 20YY
Date scheme commenced: 1 July 20XX

Ruling: Q1: Is the income you earn in Australia as a short term contractor assessable income in Australia? | A1: No. The income you earned while working in Australia is not assessable income in Australia. Your income is only taxable in Country A as you were not carrying on your professional services through a permanent establishment in Australia.

Relevant facts and circumstances: You are a resident of Country A and arrived in Australia in spring 20XX under a temporary work visa to work as a short term contractor. You left Australia in summer of that same year. When working in Australia you were represented by Company A. You worked in various activities as a contractor under contracts with multiple Australian companies. During your time in Australia you earned an amount in gross revenue. Most of your services were booked for only one day of work. You have provided a copy of the booking agreement for each customer provided by Company A for your work in Australia. Most bookings were for one day only and all were in different locations; demonstrating that you did not have a fixed base in Australia.

Relevant legislative provisions: Income Tax Assessment Act 1997 Subsection 6-5(3). | International Tax Agreements Act 1953 Section 4. | International Tax Agreements Act 1953 Section 5.