IS 21/02
Issued
19 Mar 2021

Income tax – Calculating income from personal services to be attributed to the working person

This interpretation statement provides guidance on how to calculate the amount of income from personal services that is attributed to the working person under the attribution rule in the Income Tax Act 2007. The attribution rule may apply if an entity earns income from supplying services that are personally performed by an associated person (the working person). The rule is aimed at ensuring the appropriate amount of income is recognised as being the working person’s income – so taxpayers in this situation can’t use associated entities to achieve a tax advantage.

Income Tax Act 2007: sections BC 2, BC 3, BC 4, BD 1, BD 2, BD 3, BD 4, CB 6, CE 8, DB 58, DC 8, DG 15 to DG 19, EL 4, EL 20, GB 23, GB 25, GB 25B, GB 27 to GB 29, HA 14(2), HA 15(4), HG 2 to HG 12, IA 4, IC 5, LJ 2, OB 16, and OB 40, Subparts EL and HB, and Part I