Reform of residence rules - The road ahead. 20 September 2023

Host group
Host Left
Hosted by
STEP New South Wales
Event Type

Court 13A, Supreme Court of NSW
184 Phillip St

STEP NSW Branch invites you to a seminar with Michael Bersten, Barrister, New South Wales Bar.

Topic: Reform of residence rules - The road ahead

The paper will consider the current directions for reform of the main residency tests in Australian taxation law. The current state of the law in respect of the test for individuals and non-corporate entities, as reflected in ATO Ruling TR 2023/1, will be examined by comparison to the reform agenda set out in the Treasury Consultation Paper on reform of the test published in July 2023 (itself drawing on the Board of Taxation report of 2019 and the former Government’s policy). Particular attention will be given to:

  • The demise of the “domicile” test
  • The demise of the relevance of the subjective intention of taxpayers
  • The ending of tests based on the Commissioner’s state of satisfaction
  • The corresponding rise of objective tests for the commencement and ending of residency
  • Study of the examples in ATO TR 2023/1 in light of the new test proposed in the Treasury Consultation paper.

The paper will also examine the residence of trustee companies in light of ATO taxation ruling TR 2018/5 and Practical Compliance Guideline 2018/3, noting that at this time the current Government has not announced any policy for reform of this area.

Venue: Court 13A, Supreme Court of NSW, 184 Phillip St, Sydney OR Online via Webinar

For further information or assistance, please contact [email protected]

In-person attendance is available for our Wednesday evening seminars. As this seminar has the option of 'in-person attendance' or 'remote attendance', please ensure you select the correct ticket type when registering for the event.

The seminar will be recorded and the recording will be sent to registered attendees within 7 days of the seminar.

Please note: If you are attending by live stream, the link to join the live stream will be sent to each ticket holder via email two hours before this event through the Eventbrite system.

Important reminder: To ensure you don't miss out on receiving the Zoom link, please ensure your email address is correct before confirming the ticket order.

Cost group
Event Cost
Australian Dollar
STEP Member
Australian Dollar
Non-STEP Member
17:30 - 18:30
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STEP New South Wales
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