Abc Ltd Case

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ABC Ltd

Issue:

Is ABC Ltd is a resident of Australia for tax purpose.

The definition of “resident” in S6(1)of ITAA 1936 provides that a company is a resident of Australia where it is incorporated in Australia or, not being incorporated in Australia, where it carries on business in Australia and has either its central management and control in Australia or its voting power controlled by shareholders who are residents of Australia.

Incorporation Test

Under the first statutory test, if a company incorporated in Australia is automatically resident of Australia regardless of any other factors. In this case, ABC Ltd is a palm oil company incorporated in Hong Kong, not in Australia. Therefore, this statutory test doesn’t apply.

2. Central Management

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