The Australian Taxation Office has published Interpretative Decision ATO ID 2014/20 on May 30, 2014 regarding the income of a non-resident individual engaged by a resident employer resident in Canada is taxable in Australia despite that the employee was in Australia simply on a 4 month secondment. This termination was reached on the basis that the employer had a permanent establishment in Australia by asset of having important equipment in Australia. Under both article 7(3) of the Australia – Canada Income Tax Treaty (1980) (as amended through 2002) and the domestic rules, the equipment was operated by the non-resident individual, the individual’s payment is a permissible deduction in determining the profits of the permanent establishment.
Related Posts
Australia: ATO clarifies GST registration rules for religious institutions
The Australian Taxation Office (ATO) has issued guidance on 24 August 2026, clarifying the GST obligations of religious
Read More
Australia: ATO releases draft ruling on tax treatment of crypto airdrops
The Australian Taxation Office (ATO) has released Draft Taxation Ruling TR 2026/D1 (Income tax: receipt and disposal of
Read More
US: Trump administration escalates tariff threat on Canadian automotive sector
President Donald Trump announced plans to impose 50% tariffs on all vehicles, trucks, and automotive parts originating
Read More
Canada suspends US trade negotiations, retaliates with matching tariffs
Prime Minister Mark Carney announced on 21 August 2026 that Canada's government has halted negotiations with the US
Read More
Ukraine: Cabinet reaffirms tax treaty with Australia
Ukraine’s Ministry of Finance announced on 20 August 2026 that the Cabinet of Ministers had approved a draft law
Read More
Australia tech levy takes effect against platforms avoiding news deals
Australia passed legislation on 20 August 2026 that imposes financial penalties on tech companies that refuse to pay
Read More