Working in Australian waters: The 183 day myth | KPMG | AU

Working in Australian waters: The 183 day myth for employees

Working in Australian waters: The 183 day myth

Scrutiny from the Australian Tax Office (ATO) and media on employer arrangements in connection with services performed in Australian waters has increased recently. In particular, attention has focused on the '183-day DTA exemption myth', that is pervasive within expatriate and commercial circles.


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Under this myth, it is assumed that the Dependent Personal Services (DPS) Articles in Australia's Double Tax Agreements (DTAs) will provide an exemption from Australian tax in all cases where an employee spends less than 183 days in Australia (including Australian waters). Unfortunately, this is rarely the case.

KPMG hosted a webinar on 8 March 2017, highlighting why this matter is so important.

Webinar outline:

  • Operations that create an Australian permanent establishment
  • The proper application of the DPS Article in Australia's DTAs and
  • Steps necessary to ensure Australian tax compliance.

Webinar slides

View a copy of the slide presentation from the webinar.

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