Question
Consulting Services International Ltd (CSI Ltd) is a company incorporated in Hong Kong. The company is part of a multi-national group and acts as a
Consulting Services International Ltd (CSI Ltd) is a company incorporated in Hong Kong. The company is part of a multi-national group and acts as a holding company for a number of other entities. The group provides corporate management consulting services in various countries across the globe. CSI Ltd owns 80% of the shares in Consulting Services Australia Ltd (CSA) which is incorporated in Australia and carries on a business corporate consulting in Australia through various physical offices here. CSI Ltd's main activities are raising finance and investing in order to generate funds and effectively manage the other companies in the group. CSI also provides centralised management and head office services to the other international companies in the group for fees at market value. The main income sources of CSI are therefore investment income, interest on loans to other companies and service fees. CSI's main head office is located in New York and although most of the administrative staff are also located in this New York Office, the senior executive staff, directors and Board Members are physically located at various other subsidiary company head offices in other countries. Two Board Members (from a total of 10 members) and two senior executives are based in the Australian offices but regularly travel overseas. At least two Board Meetings were held in Australia during the 2022 income year with the remaining held in New York. There were 11 Board meetings held during the year.
Required:
Discuss with reference to legislation, case law and/or rulings (where relevant) whether CSI Ltd would be considered a resident of Australia for tax purposes for the income year ended 30 June 2022.
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started