The income tax implications of a foreign individual contracting to do business in Australia, with particular reference to the concepts of 'residence' and 'source'

In order to counteract the burgeoning tax burden that may be imposed in an era of increasing international trade and travel, many countries have subsequently utilised the terms of the Model Convention as a basis for the negotiation of double taxation treaties with their trading partners. While a DTA can go a long way to ensuring that a resident of one country will not be taxed twice if he contracts to do business in a trading partner country, one must bear in mind that these treaties are of bilateral and not international application. Where an individual contracts to do business in a non-treaty partner country, he will be at the mercy of that country's domestic tax legislation.
As Australia levies taxes on the basis of residence and source, I propose to examine Australia's domestic residence and source rules applicable to foreign individuals in terms of the common law and income tax legislation, and then to review the requisite residence and source aspects of double taxation treaties.