Tom Delany


In Australia, the regime for the taxation of Personal Services Income (PSI) has suffered from being complex, unclear and uncertain, leading to poor compliance with the rules. Personal services income is defined as a reward for, or the result of, one’s personal efforts. Prior to the introduction of the regime, the tax system was plagued with a major inequity: it was possible for individuals to reduce their tax liability by alienating their PSI to an associated company (or other legal entity) and by claiming inappropriate ‘business’ deductions. This article reviews the current interpretation of the PSI rules, evaluates the Board of Taxation and the Henry Review findings and suggests an approach that reduces the potential application of Part IVA.