Corporate Residency in Australia: Back to the Future?

In an era in which countries seem to be retreating, sometimes at a rapid pace, toward source-based taxation, the importance of a sharp distinction between resident and nonresident companies becomes less obvious. In this context, the proposal by the Australian government in its 2020 budget to revamp the 90-year-old definition of resident and nonresident companies in the income tax law is significant. Over those nine decades, Australia has been something of an outlier in terms of the definition of resident companies.