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26 June 2018

Australia issues guidance on foreign companies' central management and control test of Australian residency

The Australian Taxation Office (ATO) issued three guidance documents on June 21, regarding whether foreign companies are Australian residents under Australia's central management and control (CMAC) test of corporate residency:

- Final Tax Ruling TR 2018/5 Income tax: central management and control test of residency (ruling);
- Draft Practical Compliance Guideline PCG 2018/D3 (Draft PCG) to accompany the ruling: Identifying where a company's central management and control is located; and
- A Compendium on TR 2018/5.

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Document ID: 2018-1298

 

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