Personal International Tax

Cross-border international tax planning for you and your family.

Relocating to Australia

In recent years, we’ve seen a significant increase in individuals and families looking to make Australia home - both returning Australian expats and foreign nationals. While tax isn’t commonly considered during the relocation process, due to Australia's complex tax rules and high rates of tax compared to other developed countries, it is an important consideration.

The Australian Taxation Office (ATO) has recently been focusing on private family groups with offshore wealth entering Australia. Without proper tax planning and knowledge of your Australian tax residency status, you could potentially expose yourself and your family to adverse tax consequences, such as income from your offshore investment structures being subject to the highest marginal rate of tax (47%), and in some instances, double taxation of income.

The right advice

Our dedicated community of solvers, can help you navigate the complex Australian tax requirements applicable to foreign companies, trusts and superannuation funds. Working with you either prior to, or post your arrival in Australia, our tax specialists can provide you with clarity regarding the taxation of your domestic and overseas controlled entities.


How PwC can help

We offer a broad range of services to help both individuals and families manage their international tax affairs from an Australian tax perspective.

Have you spent time abroad or are you about to move overseas? 

Are you a foreign national looking to relocate to Australia or already living in Australia and contemplating permanent residency or citizenship? 

Are you subject to an ATO review? 

How we can help:

  • Determine your Australian tax residency status under domestic law including taking into account the provisions of any relevant double tax agreement.
  • Prepare private binding ruling applications.
  • Work with legal counsel to obtain a legal opinion on tax residency. 
  • Liaise with the ATO to resolve disputes and achieve effective outcomes.

Are you moving to Australia with existing foreign structures (foreign trusts, companies or partnerships)?

Are you going overseas and want to understand the implications of any existing or new Australian structures?

Are you aware of the Australian tax consequences of holding significant foreign currency or loans?

Are you aware of your tax compliance requirements in Australia and the foreign country?

How we can help:

  • Advise on the applicable Australian and foreign tax (US/UK) implications of your existing foreign structures.
  • Advise on the applicable Australian and foreign tax (US/UK) implications of your existing foreign structures.
  • Hold a workshop session to discuss tax planning and restructure opportunities for your foreign structures.
  • Assist with Australian and US tax reporting obligations.
  • Repatriation of wealth to Australia in a tax efficient manner for business or investment purposes.

Do you participate in carried interest and/or co-investment schemes?

Do you receive deferred compensation (either in the form of cash or stock) after having spent time abroad?

Are you a non-executive director of an Australian or foreign entity? 

How we can help:

  • Advise on the Australian tax considerations of carried interest and/or co-investment schemes.
  • Review deferred compensation arrangements and provide strategies to help mitigate double tax exposure.
  • Provide guidance to you and/or your employer on non-executive director compensation and related employer obligations.

Have you worked overseas and contributed to a foreign pension scheme?

Have you considered transferring foreign pension entitlements to Australia?

Do you have an interest in a foreign life insurance or foreign life assurance policy?

How we can help:

  • Review your foreign pension scheme to understand whether it would qualify as a foreign superannuation fund for Australian tax purposes.
  • Provide  effective strategies in relation to transferring any foreign pension scheme entitlements into Australia.
  • Review the tax reporting requirements in relation to your foreign retirement benefits. 
  • Advise on distributions received from a foreign life insurance or foreign life assurance policy.

Are you expecting to receive an inheritance from an Australian or foreign deceased estate?

Have you considered both the Australian and foreign tax implications of your estate plan?

How we can help:

  • Provide effective estate tax planning in relation to assets held across multiple countries.
  • Work with a large network of estate lawyers on implementing wealth succession strategies.
  • Assist with the global tax compliance obligations for deceased estates.

Does your family office deal with multi-jurisdictional tax matters?

Are you or a family member subject to an ATO review?

Do you need help with structuring asset purchases for personal, family or investment purposes?

How we can help:

  • Complement your current family office arrangements with our international tax technical expertise.
  • Structure asset purchases for family members.
  • Assist with ATO audits, responding to ATO information requests (e.g AUSTRAC data matching requests) and assisting with any queries regarding the release of the Pandora Papers.
  • Advise on cross border Div 7A loan arrangements.
  • Access to the PwC global network of firms to provide a coordinated approach to managing cross border tax obligations.

Contact us

Justin Grealy

Partner, PwC Private, Family Office, PwC Australia

Tel: +61 478 406 645

Ryan Smith

Partner, Private - Family Office, PwC Australia

Tel: +61 412 401 344

Nathan Greene

PwC I Private I Senior Manager - Family Office, PwC Australia

Tel: +61 409 843 323