Asdflkasdf Essay

1017 Words 5 Pages
Mr Leow has been an Australian resident for tax purposes for 6 years. United Nations offered him a job in an engineering role. The service was to be rendered in Somalia. The employment contract agreement was made between Mr Leow and an independent foreign company. Mr Leow was paid $25,000 by the independent foreign company under United Nation’s supervision. Mr Leow was offered this job in June 2010 and he was out of Australia continuously from 1 August 2010 to 14 November 2010. Mr Leow argues that the income he received from the service rendered in Somalia is exempt under s23AG of ITTA36. This essay will discuss about the tax liability of the income he received by reviewing his residency, identifying the source of income and the use of …show more content…
Secondly, the source of the income received from Mr Leow’s service rendered needs to be identified for it to be taxed appropriately. To the extent of the information given, the contract was made (place of contract made unknown) between Mr Leow and the Independent Foreign Company and that the service was rendered in Somalia. The source of income can be determined from either which signing of the contract took place or the place where he rendered his service. From the information given, it is unclear where the signing of the contract took place. But it is evident that Mr Leow rendered his service as an engineer in Somalia. If the skill level of Mr Leow’s carrying job title and that the job requires highly skilled engineers, the place where the contract was made will be relevant in deciding the source of income. Otherwise, where the service was rendered will become relevant. If Mr Leow’s providing a highly skilled service, the place where he made the contract will determine his source of income. From the information given, it is likely that Mr Leow signed the contract in Australia when he received the offer in June 2010. Therefore, the source of income is from Australia and shall be taxed accordingly. Otherwise, the place where he performed such work will determine his source of income. Since Mr Laow rendered his service in Somalia, the source of income is from foreign grounds and

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