.
The ever changing landscape
- Visa, Tax & Health insurance
update
March 2017
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Disclaimer
Our comments and information contained in this presentation are generic in
nature and are not purported to represent advice that can be relied upon.
You should seek your own advice for your own circumstances.
The author or any other persons involved in the preparation or distribution of
this presentation expressly disclaim all and any contractual, tortious or other
form of liability to any person in respect of this presentation and any
consequences arising from its use by any person in reliance in whole or any
part of the contents of this presentation.
The comments contains in the presentation shall not in any way constitute a
recommendation as to whether you should invest in any product discussed in
the presentation.
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New website
• ww.skillsforhire.com.au
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Visa update
Amanda Tinner
Visa Executive
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Business travellers
Definition of business visitor activity:
•
•
•
•
Making a general business or employment enquiry
Investigating, negotiating, entering into or reviewing a business contract
An activity carried out as part of an official govt to govt visit
Participation in a conference, trade fair or seminar in Australia unless the
person is being paid by an organiser for participation
But
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Business travellers
Part of the definition states that business visitor activity does not
include any of the following activities:
• An activity that is, or includes, undertaking work for, or suppling services
to, an organisation or other person based in Australia
• An activity that it, or includes, the sale of goods or services directly to the
general public
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Business travellers
In general, activities that are not permitted are:
• engaging in employment in Australia
• Performing highly specialised work even if there is a contractual
arrangement
• Making direct sales or supplying services to the public
• Providing training, system development and/or post sales
implementation/support/maintenance
• Delivering a presentation at a conference as part of a pre-negotiated
contract that provides a material benefit to the visitor such as a
professional motivational speaker
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Business travellers
• Retail activities – making direct sales of goods or services to
the public. This includes selling goods at a trade fair
• Domestic staff such as a Nanny
• An artist selling paintings that are being promoted at a local
gallery
• An overseas lawyer participating in contract negotiations and
providing unrelated legal advice to a client – the first part is
considered a business visitor activity, the second part is work.
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Business travellers
Subclass 400
For persons seeking short-term entry to:
• Undertake non-ongoing highly specialised work OR
• Participate in non-ongoing cultural or social activities at the invitation of
or organisation operating in Australia
• 3month or 6 month stay . Period of stay starts from day of first arrival
• Cost of $275
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Business travellers
Subclass 600
– 3,6,12 month stay
– Apply onshore
– Cost $135 to $340
Subclass 601 (ETA)
– 3 month stay
– Cost of $20
– Apply offshore
The 3 visa classes depend on
your passport.
Some nationals are eligible to
apply for more than one visa
class
Subclass 651
– 3 month stay
– Apply offshore
– No cost
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Business travellers
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Business travellers
What should be in a Business Travellers Policy ?
•
•
•
•
•
•
•
Store on an app or intranet
Define business – give examples. Links to the application online
Document checklist, average processing time
Define work for the subclass 400 – give specific examples
Document checklist and sample invitation letter
One page each for business and subclass 400
Sample of travel diary
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Business travel
Berry Treffers
RDMT Consultants Pty Ltd
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Case study
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Case study
Have you ever wondered why your expatriates are so
disgruntled when it comes to health insurance?
• When on 4 September 2009 the obligation for medical expenses, incurred
in Australia during their assignment, was transferred from the company to
the individual many companies ceased providing cover under corporate
health plans and left it to the individuals to arrange.
• For those individuals (or families), who do not have access to a corporate
plan, most go on line to purchase health insurance for their Australian
assignment and purchase the most basic(cheapest) policy on line.
• Once arrived they discover the real cost of basic health insurance in
Australia for overseas visitors on 457 Visas and then frustration and noise
starts.
This is due to a number of factors but the very main factor is communication
of policy benefits.
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Case study 1
Have you ever wondered why your expatriates are so
disgruntled when it comes to health insurance?
• It is very difficult for a person from another country, when they are
advised to go on-line to seek DIBP complying health insurance, to
understand the intricacies and terminology of the Australian health
system, especially when English is not the first language.
• This is complicated by the health insurers providing the insurance
but who are prevented by legislation, from providing advice, except
for the provision of a policy benefit statement (PBS).
• Regretfully most Australian citizens do not understand our
Australian health system, and its intricacies, so what chance
that 457 Visa holders understand how the Australian health system
operates.
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Case study
What advice do expatriates receive when they log on to the
recommended DIBP website?
• Very little and what there is, is confusing.
– The 457 Visa holder logs onto a health fund and are advised that this
policy is a DIBP compliant policy.
– The health funds uses such terminology that even the most basic table
seems to provide very comprehensive cover and this policy reimburses
hospital and medical expenses @ 100% of the MBS.
– Sounds good to the 457 Visa holder as 100% ticks all their boxes.
– Except the term (MBS) is Australian terminology, unknown in any
other country, and in Australia 100% of MBS for hospital and medical
expenses does not mean 100% of actual cost.
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Case study
So what is the problem and why do your employees complain?
• The major complaints:
1.
2.
3.
Without fail - Out-of-Pocket expenses;
Medical Gaps; and
Ambulance costs.
• Medical Gaps – In-patient and out-patient
– Most basic policies are cheap for a reason as they provide very limited
benefits.
– Mostly benefits are restricted to hospital in-patient cover only and
this can create substantial out-of-pocket expenses depending on the
basic policy selected.
– Most basic policies do not cover out-patient medical expenses unless
these expenses relate to an in-patient hospital procedure.
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Case study
So what is the problem and why do your employees complain?
• Medical Gaps – In-patient and out-patient
– Most basic policies are cheap for a reason as they provide very limited
benefits.
– Mostly benefits are restricted to hospital in-patient cover only and
this can create substantial out-of-pocket expenses depending on the
basic policy selected.
– Most basic policies do not cover out-patient medical expenses unless
these expenses relate to an in-patient hospital procedure.
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Case study
Example 1
Example 2
Hospital In-patient services
• A policy may state the following:
• Most policies separate the costs for
accommodation and medical
treatment.
• I00% of cost for:
– Public and private hospital in-patient
benefits covered @ 100% of costs in a
shared ward.
– No private room.
• This means there is no out-ofpocket expense on discharge.
• These policies are rare and the
premium reflects this.
– Accommodation for overnight or same
day stays ,Operating theatre, intensive
care and labour ward fees.
– pharmaceuticals provided as part of the
in-hospital treatment
– Private room where available.
•
Followed by:
– Medical Costs - Fees charged by doctor,
surgeon, anaesthetist or other specialists
– Expenses reimbursed up to 100% of the
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Case study
So what is the problem and why do your employees complain?
• Inpatient (in hospital) medical services
– In Australia the Federal Government sets the fees that should be charged for
medical services. This schedule is known as Medicare Benefits Schedule
(MBS).
– Fees charged by a doctor, surgeon, anaesthetist or other specialist for any
treatment people have.
– If a policy states that you are covered for the cost of in-patient medical
services up to 100% of the Medicare Benefits Schedule (MBS) fee what does
that really mean?
– For example, if the MBS fee for a procedure is set at $1,500 and the doctor
charges $2,500, then this policy will pay $1,500 (100% of the MBS fee) and the
employee will be required to pay the remaining $1,000.
• However, admittance to a hospital may never happen but they will go to a
doctor or specialists, dentist, optician etc.
Then what happens?
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Case study
So what is the problem and why do your employees complain?
• Except for bulk billing clinics no doctor charges an MBS fee for a
consultation
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Case study
So what is the problem and why do your employees complain?
• These are out-of-pocket for non RHCA employees – RHCA employees can
claim from Medicare
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Case study
What do these policies cost?
•
In addition to Medicare levy of 2% - refundable for Non RHCA employees
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Case study
• Ambulance costs
– South Australia
Gazetted cost
Provision of revival team
$
3,039
Emergency call out
934
Non emergency call out
208
Treatment transport (flat
rate)
208
Plus per km rate
5.40
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Case study
Other issues that disgruntle your employees?
• Employees from RHCA countries & the Medicare Levy
Surcharge (MLS)
– Under Australian taxation law, anyone who holds a
Medicare Card (or who is entitled to hold a Medicare Card)
and does not have “appropriate” Private Health Insurance
is liable to pay a 1% to 1.5% Medicare Levy Surcharge
(MLS).
– The MLS is s calculated on income from all sources,
including exempt income earned overseas, not only
taxable income in Australia.
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Case study
Other issues that disgruntle your employees?
• What is “Appropriate” Insurance?
– “Appropriate “insurance is private patient hospital cover
which is issued by an Australian registered health fund to
Australian citizens and Permanent residents.
• Private patient hospital cover does not include:
– Travel insurance.
– Cover provided by an overseas or unregistered fund
(expatriate or Overseas visitors policies), or
– Ancillary cover (commonly known as Extras)
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• What is Migration Protect?
– Migration Protect (MP) is a tailored insurance policy cover
ing eligible candidates who migrate to Australia.
– It covers:
• Leisure travel ‐ whilst in transit and up to three months in Australi
a
• Capital benefits ‐ compensation for injury, death or disablement,
and Repatriation cover.
• Return travel on either temporary or permanent basis.
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• What is Migration Protect?
– Who is eligible to apply for Migration Protect ?
• Travellers on or applying for the following visa classes:
• Working Holiday, 457, and sponsored or nominated visa classes.
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Case study
Example 1 - Illness of family member in home country
– Steve and Connie Jones migrated from the UK to Australia after Steve
managed to land his dream marketing role. The left both Steve’s and Connie’s
elderly parents in London.
– Six months in Connie’s mother is diagnosed with Leukaemia and requires care
24/7.
– Connie needs to return home urgently to arrange full time care for her
mother.
Policy coverage
– The policy will reimburse Steve and Connie for the cost of Connie’s return
journey back to London to organise care for her mother.
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Case study
Example 2- Unemployment as a result of employer insolvency.
•
•
•
•
John Jacobs is sponsored on a 457 Visa 3 months into his role the company
experiences a significant down turn in business and John is retrenched.
John wants to stay in Australia however he knows that positions for Quality
Assurance Managers are few.
He might have transferable skills to work as an engineer in Australia but he would
need to consult a specialist in this field to know for sure.
He is also mindful that his 457 Visa condition and restrictions give him 60 days to
leave Australia and he needs to see someone about this as well.
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Case study
Example 2- Unemployment as a result of employer insolvency.
Policy Coverage
a.
b.
c.
d.
e.
The policy will reimburse John for the cost of a skills assessment consultation to determine
if his qualification can allow him to work as an Engineer and if there is a need for this
profession within Australia.
The policy will reimburse the cost of migration agent consulting fees to review his visa and
amend/extend where necessary for John to remain eligible to continue working in Australia
The policy will also reimburse the cost for a recruitment agent to put together his CV and
assist him to find a new position.
If there is a position but John has to relocate to another state or territory, the policy will
contribute towards the cost of relocation.
Should he need to return to home country the policy will contribute towards the cost of
relocation including cat and/or dog
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Who are we?
RDMT Consultants Pty Ltd is a boutique styled broking house and consulting
company which, in partnership with Health Insurance Consultants Australia
(HICA), specialise in providing medical insurance for Australian citizens,
international non-residents on 400 series Visas working, studying or travelling
in Australia and international expatriate health insurance for Australian
expatriates on international assignment.
This partnership means that we can develop solutions across a range of
complex and dynamic health risks both domestic and international.
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Tax update
Michael van Schaik
LZR Partners
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Challenges facing employers
• The line between Business Travellers & Short Term
Assignments is becoming blurred.
• Wide range of different nationalities of employees being sent
on short term assignments.
• Significant percentage of employees are unaccompanied.
• Identification of short term assignees.
• Policies need to be reviewed as many were formulated years
ago.
• Avoiding taxation problems.
• Complying with immigration regulations in multiple
jurisdictions.
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Employment structures
• Many companies adopt a so-called home country model that
attempts to maintain a ‘common law’ employment
relationship with the home country employer and loan or
‘second’ the employee to the foreign affiliate.
• This allows the employee to continue their relationship with
the home country employer for continuity and consistency of
benefits while providing a link to the host country employer
for PAYG withholding and reporting, assignment related
benefits.
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Employment structures
• How do different employment structures affect the entity and
reduce risk?
– Employment relationships should be clearly documented to support
the employer relationship, the entity benefiting from the services and
the process by which intercompany charges should be facilitated.
• Location for resolution of employment disputes
• Structure of employment contracts – choice of law
• Termination
– It will also be necessary to consider potential permanent
establishment (PE) issues in each location
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Frequent business travellers
• Many companies employ individuals who are resident in one
country, but who travel frequently to other jurisdictions to
conduct business activities:
– Business may incorrectly assume that if an individual spends less than
a specified number of days in a particular tax jurisdiction (usually 183),
there are no tax consequences resulting from the individuals activities.
– This is often not the case since the frequent business traveller may not
be resident in a treaty partner country that contains favourable
thresholds for incurring tax.
– Depending on the structure of the assignment, an individual may not
be eligible to use the treaty.
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Frequent business travellers
• Employers are becoming increasingly concerned about the
potentially adverse tax consequences caused by these
travellers.
– Countries are expanding their audit activities due to their need for
revenue to fund fiscal deficits.
– Audits related to PE, employer withholding and reporting are
becoming more frequent and aggressive. Tax authorities may inquire
about company personnel and their in-country presence.
– A significant challenge is that the business may not be aware that
frequent business travellers are present .
– Employers need to consider establishing a systems to document and
understand travel patterns and exposures.
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ATO data matching program
•
•
The ATO has advised that it will
acquire names and details of visa
holders, their sponsors, and
migration agents for the financial
years from 2013/14 to 2016/17 from
the Department of Immigration and
Border Protection.
Similar programs have been run by
the ATO over the last 5 years.
What they are seeking:
•
•
•
•
•
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•
•
•
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address history for visa applicants and sponsors
contact history for visa applicants and sponsors
all visa grants
visa grant status by point in time
migration agents (visa application preparer who
assisted or facilitated the processing of the visa)
address history for migration agents
contact history for migration agents
all international travel movements undertaken
by visa holders (arrivals and departures)
sponsor details (457 visa)
education providers (educational institution
where the student visa holder intends to
undertake their study)
visa subclass name.
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Frequent business travellers
•
•
•
•
Unlike the 457 visa, the Temporary Work - Short Stay Activity (subclass 400) visa is
applied for individually and is not an employer sponsored visa.
‘Highly specialised work’ stream:
– This stream allows individuals to apply where they hold highly specialised
skills, knowledge or experience that can assist Australian business and cannot
reasonably be found in the Australian labour market
Short term:
– Usually granted for stays of up to 3 weeks, but the maximum length is up to 6
months after the first entry.
– A longer stay will generally only be granted in exceptional circumstances
where it is demonstrated that an applicant is required in Australia for longer
than 3 months.
Non-ongoing position
– is usually considered to be one where the duties will be finalized in no longer
than 6 months.
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Frequent business travellers
• Companies should review the activities of employees who travel across
borders on business to determine whether there is any tax exposure at
either the individual or corporate level.
• A Double Tax Treaty may provide relief from personal income tax for short
term business travel under the dependent personal services article.
• However, to claim such relief, most treaties tie personal income tax liability
to whether the corporate employing entity has a PE in the host jurisdiction,
a conclusion only the corporate tax department is likely going to know.
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Short term assignments
• Employment income and ESS income is generally taxable in
Australia if the services are performed in Australia irrespective
of the individual’s tax resident status
• Only exception is via Double Tax Agreement (DTA)
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Double Tax Agreements
• Caution - even though 2 DTAs may look identical, the words of
specific articles will often differ in a material way
• TR 2001/13 - interpretation of DTAs
• Tie breaker rules - DTAs generally contain key "tie-breaker"
rules for resolving conflicts caused by taxpayers having dual
residence status
1. permanent home;
2. place of habitual abode; or
3. personal and economic relations
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Double Tax Agreements
Dependent personal services article
• Remuneration derived by a resident of a Contracting State in
respect of an employment exercised in the other Contracting
State shall be taxable only in the first-mentioned State if:
1.
2.
3.
the recipient is present in the other State for a period or periods not
exceeding in the aggregate 183 days in any twelve month period
period (or year of income for older treaties) commencing or ending
in the income year of that other State, and
the remuneration is paid by, or on behalf of, a person being an
employer who is not a resident of the other State, and
the remuneration is not borne by a permanent establishment or a
fixed base which that employer has in the other State.
• All 3 tests must be passed in order to get exemption
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ATO view on ‘employer’
•
•
•
TR 2013/1 – ATO view on 'employer'
for the purposes of the short-term
visit exception in provisions of
Australia's tax treaties.
The ATO adopts a 'substance over
form' approach.
Under Australian common law, these
factors are considered in determining
whether an employment relationship
exists in respect of particular
arrangements.
Key factors used in determining the employer:
•
•
•
•
•
•
•
•
who exercises ultimate control over the worker
who exercises day-to-day control over the
worker
Integration
the terms of engagement
who is responsible for payment of remuneration
for the worker's services
who bears the responsibility or risk for the
results produced by the worker
whether or not the contract is for the
achievement of a specified result
who provides or maintains the necessary
equipment and resources
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Income tax & DTA’s
Status
Time
Taxable in Australia
Tax rates
Non DTA location
Less than 183 days
Yes
Foreign resident
183 days or longer
Yes
Tax resident rates
Less than 183 days*
No
Non taxable
183 days or longer
Yes
Tax resident rates
Less than 183 days
Yes
Foreign resident
183 days or longer
Yes
Tax resident rates
DTA location – non
resident employer
DTA location –
Australian employer
* Always check the DTA wording
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Australian resident tax rates
2016-17
2017-18
Threshold
Rate
Threshold
Rate
$0 - $18,200
0%
$0 - $18,200
0%
$18,201 - $37,000
19.0%
$18,201 - $37,000
19.0%
$37,001 - $87,000
32.5%
$37,001 - $87,000
32.5%
$80,001 - $180,000
37.0%
$87,001 - $180,000
37.0%
$180,001
47.0%
$180,001
45.0%
* Plus Medicare levy of 2%
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Australian foreign resident tax rates
2016-17
2017-18
Threshold
Rate
Threshold
Rate
$0 - $87,000
32.5%
$0 - $87,000
32.5%
$80,001 - $180,000
37.0%
$87,001 - $180,000
37.0%
$180,001
47.0%
$180,001
45.0%
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Business and holiday
• Holiday before business meetings
– Predominant purpose
• One area of regular dispute between taxpayers and the ATO is
in connection with overseas travelling expenses.
– If a person is accompanied during business travel by a relative, the
relative's expenses are not deductible
• Self education expenses
– TR 98/9
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Travel allowance v LAFHA
See MT 2030
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Travel allowances
• A Travel Allowance is paid because the employee is travelling in the course
of performing their job.
– The allowance is usually applicable for comparatively short-term periods (i.e. up to 21
days).
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Travel allowances
• The substantiation exception from substantiation for workrelated expenses covered by an overseas travel allowance
applies only to expenses for food, drink and incidentals.
• The exception does not apply to accommodation costs.
• See TR 2004/6
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Travel allowances
• Substantiation requirements – TR 2004/6
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LAFHA summary
If your employee
Then the taxable value is
 Maintains a home in Australia at which they
usually reside and it is available for their use at
all times,
 Receives a LAFHA fringe benefit which relates to
the first 12-month period at a particular work
location, and
 Gives you the appropriate declaration about
living away from home
The amount of the LAFHA paid, minus:
 any exempt accommodation component, and
 any exempt food component.
 Works on a fly-in fly-out or drive-in drive-out
basis
 Has residential accommodation at or near their
usual place of employment, and
 Gives you the appropriate declaration about
living away from home
The amount of the LAFHA paid, minus:
 any exempt accommodation component, and
 any exempt food component.
 Does not fall into either of the above situations
The amount of the fringe benefit
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Fringe benefits
Fringe benefits provided whilst working overseas
• Fringe benefits are non-assessable non-exempt income under Australian
tax law, but potentially included as assessable income in the overseas
jurisdiction.
• Employee may be liable to foreign tax on LAFHA received.
• BUT foreign tax paid with respect to LAFHA is not eligible for FITO
purposes and therefore lost!
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Fringe benefits
TD 2011/1 which sets out the ATO’s view that a non-resident entity:
•
is required to withhold PAYG amounts from salary and wages paid to an Australian
resident employee for work performed overseas, if the non-resident entity has a
sufficient connection with Australia, and
•
is subject to FBT in relation to benefits provided to that employee if there is a
withholding obligation.
•
the non-resident entity will have a sufficient connection to Australia if it has a
physical business presence in Australia.
•
Will have physical business presence in Australia if the non-resident carries on an
enterprise or income producing activities (or part of such enterprise or activities)
in Australia and has a physical presence in Australia.
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Fringe benefits
Example from TD 2011/1:
•
•
•
Sheree is an Australian resident for tax purposes. She is employed as a project
manager working in the Australian operations of a non-resident consultancy
company. The company transfers her overseas for 5 months to work on a new
consultancy project. The company continues to carry on business and maintains a
physical presence in Australia. Sheree's wages are assessable income in Australia.
The company has an obligation to withhold an amount for Australian tax purposes
from the salary paid to her.
Sheree is provided with a car while overseas and is reimbursed for some additional
living expenses. As amounts must be withheld from her salary, her employer will
have obligations under the FBTAA in respect of the benefits provided to her.
Sheree is not required to include these in her Australian assessable income.
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Fringe benefits
Example from TD 2011/1 – different result:
•
Lauren is an Australian resident for tax purposes. She works for an Australian subsidiary of an
international hotel chain as an events manager. Under an incentive program for high
performing staff, she is offered a 6 month overseas secondment with the group's global
parent company. The parent company is a non-resident for tax purposes and does not carry
on business in Australia. While on secondment she will be employed and paid by the parent
company.
•
Her employer, being the non-resident parent company not carrying on business in Australia
and with no physical presence in Australia, has no obligation to withhold Australian tax from
the salary paid to her. As there is no obligation to withhold, no obligations under the FBTAA
can arise to her non-resident employer in respect of any benefits provided to her.
•
Lauren will be required to include this employment income and the value of any benefits
received from the non-resident employer in her Australian assessable income
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Superannuation Guarantee
Minimum superannuation support required, unless:
• persons who receive salary and wages but are "prescribed
employees" for the purposes of the regulations under SGAA
– Typically senior executives who would have qualified for thr former
413 visa
• foreign employees who are paid for work done outside
Australia (except to the extent that the salary or wages relate
to employment covered by a certificate under s 15C in
relation to an international social security agreement): and
• resident employees who are employed by foreign resident
employers and are paid for "work done outside Australia“.
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Backpacker tax
• On 1 January 2017, tax rates changed for working holiday makers
who are in Australia on a 417 or 462 visa.
• If you employ a working holiday maker on a 417 or 462 visa:
– You must register with the ATO so you can withhold the correct
amount tax.
– You should withhold 15% from every dollar earned up to $37,000 with
foreign resident tax rates applying from $37,001.
– If you don’t register you need to withhold at the foreign resident tax
rate of 32.5% from the first dollar earned.
• If you employed a working holiday maker before and after 1
January 2017, you need to issue two payment summaries for this
financial year
– one for income earned up to 31 December 2016; and
– one for income earned from 1 January 2017 (using gross payments
type H).
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Questions
Karl
.
Contact details
Michael van Schaik
LZR Partners
Phone: 0418 844 105
Email: [email protected]
Amanda Tinner
Visa Executive
Phone : 0409 969 525
Email: [email protected]
Berry Treffers
RDMT Consultants & HICA
Phone: 0434 485 331
Email: [email protected] or [email protected]
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