Australia issues final tax guidance on central management and control test for foreign companies

The Australian Taxation Office has issued final taxation guidance setting out how the government views the central management and control test, which aids in the determination of whether a foreign company is considered an Australian resident tax purposes.

Final ruling TR 2018/5, finalizes draft Australian guidance on the management and control test issued in March 2017. The new guidance is effective June 21.

The ATO also issued draft Practical Compliance Guideline PCG 2018/D3, containing practical guidance to assist foreign incorporated companies and their advisors in applying the principles set out in TR 2018/5.

Comments on the draft are requested by July 20.