No satisfaction: Unique application of residency test in Addy case

As detailed by Keith Swan, Priscilla Tang, Terry Hoban and Alice Chow, a tax residency case highlights the need for taxpayers to collate relevant information and prepare a strategy to engage the ATO.

The number of court cases relating to the tax residency of individuals has grown over the last 12 months, including the recent Full Federal Court decision in Commissioner of Taxation v Addy [2020] FCAFC 135 (Addy).The taxpayer filed an application for special leave to appeal to the High Court on 4 September 2020.   The case is more widely known as a matter funded under the Australian Taxation Office (ATO) Test Case Litigation Program regarding the operation of Article 25 of the Aust...

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Authors: Keith Swan, Priscilla Tang,

Published Date: 18 September 2020