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NO Ref.: 85/4612-6 Date of effect: Immediate

BO Ref.: Date original memo issued:

EDR Ref: 37

FOI INDEX DETAIL

Reference no.: Subject refs: Legislative refs:

I 1012811 RESIDENCY 6(1)
PERMANENT PLACE OF
ABODE OUTSIDE
AUSTRALIA

OTHER RULINGS ON THIS TOPIC: IT 2221, 2268, 2607

TITLE: INCOME TAX: RESIDENCY - PERMANENT PLACE OF ABODE
OUTSIDE AUSTRALIA

NOTE: . Income Tax Rulings do not have the force of law.

. Each decision made by the Australian Taxation Office

is made on the merits of each individual case having
regard to any relevant Ruling.

PREAMBLE

The purpose of this Ruling is to provide guidelines for

determining whether individuals who leave Australia temporarily to
live overseas, for example, on temporary overseas work assignments
or on overseas study leave, cease to be Australian residents for
income tax purposes during their overseas stay. This preamble
outlines various matters that are relevant to the content of this
Ruling, under appropriate headings.

Statutory Definition

2. The terms "resident" and "resident of Australia" are defined

in subsection 6(1) of the Income Tax Assessment Act 1936. So far
as an individual is concerned, these terms are defined to mean:

"(a) a person, other than a company, who resides in Australia

and includes a person-

(i) whose domicile is in Australia, unless the

Commissioner is satisfied that his permanent place
of abode is outside Australia;
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(ii) who has actually been in Australia, continuously or

intermittently, during more than one-half of the
year of income, unless the Commissioner is
satisfied that his usual place of abode is outside
Australia and that he does not intend to take up
residence in Australia; or

(iii) who is an eligible employee for the purposes of the

Superannuation Act 1976 or is the spouse or a child
under 16 years of age of such a person; "

3. The above definition, in effect, provides four tests to

ascertain whether an individual is a resident:

. residence according to ordinary concepts;

. the domicile and permanent place of abode test;
. the 183 day test; or
. the Commonwealth superannuation fund test.

4. This Ruling focuses on the first two tests referred to in

paragraph 3, being the tests most widely applicable to persons who
ordinarily reside in Australia but who leave Australia temporarily
and are not actually living in Australia during the year of
income.

Summary of Ruling

5. The Ruling concludes, bearing in mind the wide, general

language used in the first test in the "resident" definition, and
the state of satisfaction which must be reached in the second
test, that it is not possible to provide conclusive rules for
determining the residency status of individuals leaving Australia
temporarily. The Ruling says, however, that the following factors
need to be taken into account:

(a) the intended and actual length of the individual's stay

in the overseas country;

(b) any intention either to return to Australia at some

definite point in time or to travel to another country;

(c) the establishment a home outside Australia;

(d) the abandonment of any residence or place of abode the

individual may have had in Australia;

(e) the duration and continuity of the individual's

presence in the overseas country; and

(f) the durability of association that the individual has

with a particular place in Australia.
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The weight to be given to each factor will vary with individual

circumstances of each case and no single factor is conclusive.

Possibility that person may be resident in two countries

6. This Ruling deals only with the question of residency for

the purposes of Australia's income tax laws. However, the fact
that a person is a resident of Australia for Australian income tax
purposes does not mean that the person may not also be a resident
of another country for the purposes of that country's taxation
laws. A number of double taxation agreements to which Australia
is a party recognise the possibility of a person being a resident
of two countries, in other words, a person may have dual
residency. Those agreements provide rules for determining the
country of which the person is deemed to be a sole resident.
Therefore, if a person is considered to be a resident of Australia
as well as a resident of another country, regard must be had to
the terms of the particular double taxation agreement in
determining the person's residency status. A dual resident, who
is treated as solely resident of another country for the purposes
of the relevant double taxation agreement, remains a resident of
Australia for the purposes of the Income Tax Assessment Act
(compare paragraph 5 of Taxation Ruling IT 2607).

Definitions

"Reside"

7. The ordinary meaning of the word "reside", according to the

Shorter Oxford English Dictionary, is to dwell permanently, or for
a considerable time, to have one's settled or usual abode, to live
in or at a particular place.

"Domicile"

8. "Domicile" is a legal concept to be determined according to

the Domicile Act 1982 and to the common law rules which the courts
have developed in the field of private international law. The
primary common law rule is that a person acquires at birth a
domicile of origin, being the country of his or her father's
permanent home. This rule is subject to some exceptions.
For example, a child takes the domicile of his or her mother if
the father is deceased or his identity is unknown. A person
retains the domicile of origin unless and until he or she acquires
a domicile of choice in another country, or until he or she
acquires another domicile by operation of law (Henderson v.
Henderson [1965] 1 All E.R.179; Udny v. Udny [1869] L.R.1 Sc.&
Div. 441; Bell v. Kennedy [1868] L.R.1 Sc.& Div. 307 (H.L.)) .

9. The common law test of domicile of choice has now been

restated in section 10 of the Domicile Act which provides:
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"The intention that a person must have in order to acquire a

domicile of choice in a country is the intention to make his
home indefinitely in that country."

In addition, that Act abolished the former common law rule whereby
a married woman had at all times the domicile of her husband.

10. In determining a person's domicile for the purposes of the

definition of "resident" in subsection 6(1), it is necessary to
consider the person's intention as to the country in which he or
she is to make his or her home indefinitely. Thus, a person with
an Australian domicile but living outside Australia will retain
that domicile if he or she intends to return to Australia on a
clearly foreseen and reasonably anticipated contingency e.g., the
end of his or her employment. On the other hand, if that person
has in mind only a vague possibility of returning to Australia,
such as making a fortune (a modern example might be winning a
football pool) or some sentiment about dying in the land of his or
her forebears, such a state of mind is consistent with the
intention required by law to acquire a domicile of choice in the
foreign country - see In the Estate of Fuld (No. 3)(1968) p. 675
per Scarman J at pp. 684-685 and Buswell v. I.R.C (1974)
2 All E.R. 520 at p. 526.

"Permanent place of abode"

11. Having established that a person has his or her domicile in

Australia, subparagraph (a)(i) of the definition of "resident"
requires the Commissioner to be satisfied that the person's
"permanent place of abode" is not outside Australia.

"Place of abode"

12. The expression "place of abode" refers to a person's

residence, where one lives with one's family and sleeps at night
(R v. Hammond (1852) 117 E.R. 1477 at p. 1488; Levene v.
I.R.C.(1928) A.C.217 and I.R.C. v. Lysaght (1928) A.C.234).
In essence, a person's "place of abode" is that person's dwelling
place or the physical surroundings in which a person lives.

"Permanent"

13. The leading case on whether a permanent place of abode is

outside Australia is F.C. of T. v. Applegate (79 ATC 4307;(1979)
9 ATR 899). The taxpayer, whose domicile was in Australia, had
been sent by his employer, a firm of solicitors, to establish a
branch office in Vila, New Hebrides. His absence was to be for an
indefinite period in the sense that the period was not specified
or defined but it was expected that it would be of a substantial
length. It was also expected that later he would be recalled to
Australia. In fact, he returned to Australia after 2 years, his
stay being cut short by illness. The taxpayer claimed that the
salary he earned in Vila was exempt from Australian tax being
income derived by a non-resident from sources wholly out of
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Australia. In that case, it was decided that, because the

taxpayer could not be considered to have resided in Australia
under the ordinary meaning of the word "reside", the extended
definition of "resident" contained in paragraph (a)(i) had to be
considered. Both the Supreme Court of New South Wales and, on
appeal, the Full Court of the Federal Court of Australia held that
the taxpayer had a permanent place of abode outside Australia.
He was therefore a non-resident in the year of income concerned.

14. The Federal Court rejected the Commissioner's argument that

a permanent place of abode outside Australia required an intention
to live outside Australia indefinitely without any intention of
returning to live in Australia in the foreseeable future, other
than at some remote, albeit specific, point of time. The Court
said that the term "permanent" must be interpreted in the context
in which it appears. The Court said that in its context in the
"resident" definition a permanent place of abode does not have to
be "everlasting" or "forever". It means something less than a
permanent place of abode in which a person intends to live for the
rest of his or her life. It should be contrasted with a temporary
or transitory place of abode outside Australia. It connotes a
more enduring relationship with the particular place of abode than
that of a person who is ordinarily resident there or who has there
his or her usual place of abode. An intention to return to
Australia in the foreseeable future to live does not prevent the
taxpayer in the meantime setting up a "permanent place of abode"
elsewhere. The Federal Court also found that the taxpayer's
intention regarding the duration of his stay overseas was only one
relevant factor to be taken into account. Of more importance is
the nature and quality of use which the taxpayer makes of a
particular place of abode overseas.

15. "Permanent place of abode", according to Fisher J

(79 ATC at 4317; 9 ATR at 910-911), is :

..."the taxpayer's fixed and habitual place of abode. It is

his home, but not his permanent home. It connotes a more
enduring relationship with the particular place of abode
than that of a person who is ordinarily resident there or
who has there his usual place of abode. Material factors
for consideration will be the continuity or otherwise of the
taxpayer's presence, the duration of his presence and the
durability of his association with the particular place".

16. The case of F.C. of T. v. Jenkins 82 ATC 4098; (1982)

12 ATR 745, involved a bank officer who had been transferred to
the New Hebrides for 3 years. He returned to Australia after only
18 months because of ill health. The taxpayer had tried to sell
the family home before going overseas but was unable to find a
buyer. The Australian home was eventually leased and the taxpayer
retained a bank account in Australia.

17. The Supreme Court of Queensland held that the taxpayer had a
permanent place of abode outside Australia during the period he
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was overseas even though he had not at any material time formed an
intention to remain indefinitely in the New Hebrides in the sense
in which the word "indefinitely" is used in Applegate. Sheahan J
considered that if a stay of 10 years could not sensibly be
regarded as "temporary", neither should a stay of 3 years be so
regarded. In giving evidence, the taxpayer had said that, under
normal circumstances, he and his wife would have applied for an
extension after the 3 years had lapsed. In addition, they had no
fixed date on which to return to Australia until the taxpayer fell
ill.

RULING

18. Liability to tax arises annually and the question where a

taxpayer resides must be determined annually according to the
facts applicable to the particular year of income under
consideration. However, events which have happened since the end
of the tax year may be taken into account in determining that
question (Applegate per Franki J 79 ATC at p.4309; 9 ATR at
p.902).

19. The first question to be asked in considering the residency

status of a person temporarily leaving Australia, is whether he or
she can be considered to reside in Australia. If the test of
residence according to ordinary concepts is satisfied, there is no
need to go any further. The person is a resident of Australia for
income tax purposes.

20. The extended definition contained in subparagraph (a)(i) of

the definition of "resident" is alternative to the ordinary
meaning of the term "resides" (Applegate 79 ATC at p.4314; 9 ATR
at p.907). In other words, even if the person is found not to
"reside" in Australia within the ordinary meaning of the word, he
or she may still fall within the extended definition of
"resident". Conversely, if the person does "reside" in Australia
within the ordinary meaning of that word, it is not necessary to
determine whether the extended definition is satisfied.

Domicile

21. Generally speaking, persons leaving Australia temporarily

would be considered to have maintained their Australian domicile
unless it is established that they have acquired a different
domicile of choice or by operation of law. In order to show that
a new domicile of choice in a country outside Australia has been
adopted, the person must be able to prove an intention to make his
or her home indefinitely in that country e.g., through having
obtained a migration visa. A working visa, even for a substantial
period of time such as 2 years, would not be sufficient evidence
of an intention to acquire a new domicile of choice.
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Permanent Place of Abode

22. The word "permanent" in subparagraph (a)(i) of the

definition of "resident" does not have the meaning of everlasting
or forever but is used in the sense of being contrasted with
temporary or transitory (Applegate 79 ATC at p.4314; 9 ATR at
p.907).

23. It is clear from Applegate and Jenkins that a person's

permanent place of abode cannot be ascertained by the application
of any hard and fast rules. It is a question of fact to be
determined in the light of all the circumstances of each case.
Some of the factors which have been considered relevant by the
Courts and Boards of Review/Administrative Appeals Tribunal and
which are used by this Office in reaching a state of satisfaction
as to a taxpayer's permanent place of abode include :

(a) the intended and actual length of the taxpayer's stay

in the overseas country;

(b) whether the taxpayer intended to stay in the overseas

country only temporarily and then to move on to another
country or to return to Australia at some definite
point in time;

(c) whether the taxpayer has established a home (in the

sense of dwelling place; a house or other shelter that
is the fixed residence of a person, a family, or a
household), outside Australia;

(d) whether any residence or place of abode exists in

Australia or has been abandoned because of the overseas
absence;

(e) the duration and continuity of the taxpayer's presence

in the overseas country; and

(f) the durability of association that the person has with

a particular place in Australia, i.e. maintaining bank
accounts in Australia, informing government departments
such as the Department of Social Security that he or
she is leaving permanently and that family allowance
payments should be stopped, place of education of the
taxpayer's children, family ties and so on.

Weight of factors

24. The weight to be given to each factor will vary with the
individual circumstances of each particular case and no single
factor will be decisive. Applegate seems to indicate, however,
that greater weight should be given to factors (c), (e) and (f)
than to the remaining factors, though these are still, of course,
relevant. The fact that a taxpayer knows that he or she will
return to Australia at a definite point in time (factor (b)) does
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not, of itself, mean that he or she does not have a permanent

place of abode outside Australia.

Factor (a) - length of overseas stay

25. Clearly, the longer an individual's stay in any one

particular place, the more permanent in nature and quality of use
is likely to be the stay in that place of abode. An individual's
intention regarding the duration of the overseas stay and the
length of the actual stay are only relevant factors. Where a
taxpayer leaves Australia for an unspecified or a substantial
period and establishes a home in another country, that home will
represent a permanent place of abode of the taxpayer outside
Australia, subject to a consideration of the other factors listed
in paragraph 23 above. As a broad rule of thumb, a period of
about 2 years or more would generally be regarded by this Office
as a substantial period for the purposes of a taxpayer's stay in
another country. It must be stressed, however, that the duration
of the taxpayer's actual or intended stay out of Australia is not,
of itself, conclusive and needs to be considered with all of the
factors in paragraph 23 above.

26. If, however, an individual with a usual place of abode in

Australia has no fixed or habitual place of abode overseas but
moves from one country to another or moves constantly within the
same country ( for example, from town to town or even from suburb
to suburb) any association with a particular place overseas would
be purely temporary or transitory and he or she would not be
considered to have adopted an alternative domicile of choice or a
permanent place of abode outside Australia. In such case, if the
person could not be said to have acquired a domicile of choice
outside Australia, the taxpayer would be considered to be a
resident of Australia under subparagraph (a)(i) of the definition
of "resident". On the other hand, a person may be considered to
have a permanent place of abode in an overseas country where he or
she establishes a home in that country notwithstanding that he or
she moves to another home in the same country, subject to a
consideration of the other factors listed in paragraph 23.

27. Generally speaking, a taxpayer who leaves Australia with an

intention of returning to Australia at the end of a transitory
stay overseas would remain a resident of Australia for income tax
purposes unless he or she can satisfy the Commissioner that a
consideration of the other factors listed in paragraph 23 requires
the conclusion that during the year of income his or her permanent
place of abode was outside Australia. What constitutes a mere
transitory stay overseas for these purposes would vary with the
circumstances of each case. However, as a general proposition, an
overseas stay for a duration of less than 2 years would be
considered as being of a transitory nature. It is stressed that
the duration of the taxpayer's stay overseas is not of itself
conclusive and must be considered with all the other factors
listed in paragraph 23.
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Factor (c) - Whether the taxpayer has established a home outside

Australia

28. The fact that an individual has established his or her home
(in the sense of a dwelling place; a house or other shelter that
is the fixed residence of a person, family or household) in an
overseas country would tend to show that the place of abode in the
overseas country is permanent. Acquisition of a home in the
overseas country would be a very relevant though not conclusive
factor. On the other hand, individuals or a family group who
"make do" in temporary accommodation with limited resources and
facilities such as in barracks, singles' quarters, aboard ships,
oil rigs, or mining towns, will be less likely to be considered to
have established a permanent place of abode overseas.
Factor (f) - Durability of association with a particular place in
Australia

29. The relevance of bank accounts maintained in Australia

varies depending on the types of accounts. If a taxpayer closes
all bank accounts in Australia and transfers all funds (including
investment funds) to accounts in the overseas country, this would
indicate less durability of association with a place in Australia
than if all accounts in Australia were maintained. On the other
hand, even if an individual closes all accounts for everyday use
(such as cheque and savings accounts) and maintains a long term
investment account, it is still possible to establish that, on the
basis of other factors, the individual has a permanent place of
abode in the overseas country.

30. Similar considerations apply in relation to the place of

education of children. For example, an individual may be
considered to have a permanent place of abode in an overseas
country even though his or her children continue their schooling
in Australia due to the absence of adequate educational facilities
in the overseas country. However, the fact that the children
continue their schooling in Australia despite the presence of
adequate educational facilities in the overseas country, would
tend to show a more durable association with a place in Australia.

EXAMPLES

31. An Australian resident employee of a mining company was

transferred overseas for a temporary work assignment for a period
of 2 years and intended to return to Australia at the end of that
period. The purpose of the assignment was for the employee to
gain wider work experience. The employee was initially
accompanied by his wife and children but the children returned to
Australia to continue their schooling. The employee spent his
annual holiday in Australia. During his absence from Australia he
rented out his home and maintained bank accounts in Australia.
He made no investments in the overseas country and remitted all
money in excess of living requirements to Australia for
investment. In those circumstances the taxpayer was not
considered to be a resident of Australia under the ordinary
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meaning of the word "resident" but was considered to be a resident

under the extended definition of that term.

Result: resident.

32. A person who had just completed tertiary studies decided to

leave Australia for an unspecified period of time to work in one
overseas country to gain work experience. Before leaving she
closed all bank accounts except for a 5-year interest bearing
deposit. She had no established home in Australia and no spouse
or children in Australia. While she was forced to return to
Australia within 18 months due to an illness, she was considered
to be a non-resident as it was her original intention to remain
outside Australia for an unspecified period of time and she was
considered to have a permanent place of abode in the overseas
country.

Result: non-resident.

The opposite conclusion would have been reached if she had

intended to (and did) spend one year each in 2 countries and then
had travelled for a further period of one year, making do in
temporary or transitory accommodation in each country as she went.
In that case she would not have a permanent place of abode in any
of the overseas countries and would continue to be a resident of
Australia.

Result: resident during the 3-year overseas stay.

33. A bank manager was posted to the New Hebrides for 2 years.
During that time he and his family lived in a furnished house
provided by the bank. The taxpayer's home in Australia was let.
On leaving Australia, the taxpayer expected a further overseas
posting after his 2-year period. He advised the Department of
Social Security that the family was leaving Australia permanently
and child endowment payments should cease. The taxpayer was
considered to have abandoned his place of residence in Australia
and to have formed the intention to, and in fact did, reside
outside Australia. His place of abode in Vila was not merely
temporary or transitory; rather, it was intended to be and was in
fact his home for the time being (Case S19 85 ATC 225;
28 CTBR (NS) Case 29).

Result: non-resident.

34. A bank officer was posted from Australia to the New Hebrides
for 2 years only and never intended to stay any longer.
During his overseas posting he maintained bank accounts in
Australia, into one of which family allowance payments continued
to be made, and let his Australian home unfurnished. He was
accompanied by his wife and children. His place of abode in the
New Hebrides was considered to be temporary or transitory for two
reasons. Firstly, he lived, by the bank's continuing permission,
in a house leased by the bank in the New Hebrides. Secondly,
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having regard to the 2-year period of his appointment, the

taxpayer's relationship with his place of abode in Port Vila
lacked " a more enduring relationship" (see Applegate per Fisher J
79 ATC at p.4317; 9 ATR at pp 910-911) with the particular place
of abode than that expected to exist where a person ordinarily
resides there or has there his usual place of abode (Case Q68 83
ATC 343; Case 132 26 CTBR(NS) 913).

Result : resident.

35. An engineer was sent by his Australian employer to the

Philippines on a project assignment for a minimum period of 3 to 4
years and he decided to relocate his family in the Philippines.
In fact, the assignment was terminated after 2 years and the
taxpayer returned to Australia. It was always his intention to
return to Australia at the completion of the project. He retained
his Australian home and rented it out. On arriving in the
Philippines, the taxpayer and his family initially resided for
short periods at a hotel and in an apartment. Later, he sub-leased
a house which the family occupied until their return to Australia.
Having regard to the nature and quality of his use of the place of
abode in the Philippines, the taxpayer was considered to have
established a permanent place of abode outside Australia (Case R92
84 ATC 615; Case 145 27 CTBR(NS) 1131).

Result : non-resident.

36. An Australian chartered accountant was seconded to his

employer's London office for a period of 2 years or "such longer
period as mutually agreed upon". After arriving in London the
taxpayer and his wife bought an apartment and lived there for one
year and later used rented accommodation, all the time renting out
his Australian home. In the event, the taxpayer did not accept the
offer to stay on with the firm after his initial period of
employment largely due to the fact that his wife wished to return
to Australia. After an extended holiday in Europe, he returned to
Australia. In view of his decision to purchase the matrimonial
home in London and not to stay overseas solely for the basic
period of the 2-year secondment, the taxpayer was considered to
have a permanent place of abode outside Australia (Case T28
86 ATC 276; 29 CTBR (NS) Case 31).

Result : non-resident.

37. An Australian missionary went overseas for a period of 4 to

6 years with the probability of again being posted overseas for a
similar period after completion of her furlough leave in
Australia. She and her husband owned a house in Australia which
they rented out during their absence. They intended to return to
Australia at the end of their missionary work. She was considered
to be a non-resident during the period of her absence overseas
(Case Q95 83 ATC 472; 27 CTBR (NS) Case 18). However, during the
period of furlough in Australia and while she was in Australia
awaiting reappointment to another overseas post, she was not
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considered to have a permanent place of abode outside Australia

and was a resident of Australia.

Result: non-resident during the overseas absence.

38. An airline company employee took a 2 to 3 year posting to an

overseas country expecting to return to Australia at the end of
that period. She was accompanied by her spouse and children and
purchased a home in the overseas country while renting out the
family home in Australia. She was considered to have remained a
resident of Australia. However, if she decided to stay in the
overseas country for a further period of, say, 2 years, she was to
be treated as a non-resident during the additional 2 year period.

Result: resident during her posting.

39. An engineer went to a developing country to manage an aid

project. He received a salary supplement paid under an Australian
Government assistance scheme. He expected to remain in the
overseas country for 18 months and then to obtain a posting to
manage a similar project in another developing country. He was
considered to have a permanent place of abode in the overseas
country and to be a non-resident of Australia. A different
conclusion may have been reached if it had been his intention to
return to Australia at the end of the first posting.

Result: non-resident.

40. An advertising executive secured a position with a U.K. firm

and undertook to work in London for 20 months. She sold her home
in Australia and purchased a home in the U.K. She enrolled her
two children in a secondary school near the new home which they
attended for 2 years. She had no other close family ties in
Australia. At the end of the 20 months, she decided to extend her
stay by 1 year. She was considered to have a permanent place of
abode in the U.K. and not to be a resident of Australia.

Result: non-resident.

40. A person who went to the U.K. to work for 3 years and
established a place of abode there was not considered to be an
Australian resident during that period. At the end of the 3-year
period, before returning to Australia she travelled around France
for one year and Spain for another year, combining travel and
casual employment. During the additional two years, she was not
considered to have a permanent place of abode in either Spain or
France and was therefore a resident of Australia.

Result: non-resident during the first three years but a resident

for the next two years.

41. A taxpayer with an Australian domicile and an established home

in Australia established a second home in an overseas country.
The taxpayer and his family spent just over 6 months at the
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overseas home and the rest of each year in his Australian home.
Because of the length of the taxpayer's stays in Australia, the
duration of his presence overseas and the lack of continuity of
his presence overseas led to the conclusion that he had not
established a permanent place of abode in the overseas country.
This conclusion was supported by the extent of his durability of
association with his home in Australia.

Result: resident.

42. A businessman operating an import/export business spends

over 6 months every year in the overseas country with which most
of the business is carried out. His wife travels with him during
the 6-month stay overseas. Their children, aged between 20 and
32, live in Australia. The businessman owns a home in Australia
where he lives for just under 6 months each year and a home in the
other country where he lives the rest of the time. He holds
investments and other accounts in both countries. Because of the
length of his stays in Australia, the conclusion was reached,
having regard to the duration of his presence overseas and the
lack of continuity of his presence overseas, that he had not
established a permanent place of abode in the overseas country.
This conclusion was supported by the extent of the durability of
his association with Australia. In the absence of evidence that
he had adopted a domicile of choice in the other country (for
example, a migration visa to the other country), he was considered
to be a resident of Australia and therefore subject to Australian
income tax on all income derived by him.

Result: resident.

COMMISSIONER OF TAXATION
8 August 1991

ISSN 0813 -3662 Price $1.30

 TAXATION RULING IT 2650

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