EV 1052236101874currentnon-binding advice

Foreign employment income - double tax agreement

Non-binding edited private advice. This is an edited version of private advice the ATO gave to a specific taxpayer about their own circumstances. You cannot rely on it — it is not binding and provides no protection for anyone else (see PS LA 2008/4). Use it as a guide to the ATO’s thinking, not as authority.

1

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?

2

Yes. This ruling applies for the following periods : Year ended 30 June 20XX The scheme commenced on: XX XXX 20XX

3

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