Tax Opinion — ONUS Directors

Does Your Director
Arrangement Actually
Protect You?

If you are an Australian tax resident who owns a Singapore company, your nominee director arrangement may be creating the very tax residency risk it was designed to avoid. Complete the short survey to access the full legal opinion.

Legal Opinion — General Australian Tax Advice

Foreign Companies using "Nominee Directors" as their offshore director for the purposes of maintaining central management and control outside of Australia

Prepared by RP Private Ltd

Date 21 October 2025

Author Tristan Perry FCA

Tax Agent #25870612

4 pages

13 ATO assessment factors used to determine where central management and control is exercised

Bywater Investments [2016] HCA 45 — the High Court decision that changed everything

ROND & BizFile disclosure — nominee status now publicly reported to 100+ tax authorities

30% Australian corporate tax — the consequence of a foreign company being deemed an Australian resident

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