This presentation covers:
- why is the determination of "source" important?
- when does the determination of "source" become critical?
- what is the meaning of the "source" of income?
- common law "source" rules
- statutory "source" rules
- under Australia's double tax agreements ("DTAs")
- what is the meaning of Australia and what is its impact on the determination of "source"?
- what complexities can arise when determining "source"?
- current issues relating to the "source" of income.