Taxation Ruling TR 2018/5 sets out the Commissioner of Taxation’s views as to when a foreign incorporated company will be considered a resident in Australia for tax purposes.
The ruling is in response to the High Court Decision in Bywater Investments Limited v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation [2016] HCA 45
Further insight into Tax Office thinking on the matter is found in its Practical Compliance Guideline PCG 2018/D3 which is open for public comment.