The Australian Taxation Office (ATO) has published Taxation Ruling (TR) 2018/5, which sets out the Commissioner's view on how to apply the central management and control test of company residency following a court case finalized in November 2016 where four offshore companies were deemed to be resident in Australia for tax purposes ({News-2016-11-18/A/2-previous coverage}).
Under the central management and control test, a company may be considered a resident of Australia if it carries on busi…