The central management and control test for determining residency of a company has been problematic. The uncertainties in the test were addressed by Taxation Ruling TR 2004/15. The author believes the Ruling has done little to clarify the operation of the test. Legislative reform is recommended to ensure that the central management and control test does operate more effectively
"Still a Problem Child : Central Management and Control after RITA,"
Revenue Law Journal:
1, Article 7.
Available at: http://epublications.bond.edu.au/rlj/vol15/iss1/7