Coventry v CofT – DFAT employee’s overseas earnings exempt from Australian tax, under s23AG, because diplomatic immunity was not ‘the only’ reason for no Pakistani tax (and draft DIS)

On 12 January 2018, the AAT has decided that a DFAT employee’s earnings while working in Pakistan were exempt under s 23AG of the ITAA 1936. This was because there was a Development Agreement, that gave the earnings exemption from Pakistani tax. I will explain why. Section 23AG(1) exempts, from Australian tax, any foreign earnings derived by…

EU proposing to ‘go it alone’, in taxing ‘digital’ services, whilst waiting for OECD/G20 multi-lateral initiatives to tax these services

On 21.3.18, the European Commission proposed new rules to tax digital business activities – ‘going it alone’, ahead of any consensus from the OECD/G20. In response to this, the Australian Treasurer was reported as saying: ‘that Australia, like other G20 nations, might go it alone with measures to tax digital economy companies, like Uber, because…