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DNV GL Latest Research Helping Shipowners Decarbonise Fuel + Engines



New Research from DNV GL Helps Shipowners Choose Fuels and Engines to Keep Vessels Commercially Viable in a Decarbonizing World

Decarbonizing shipping will require faster technology development, large-scale piloting and appropriate safety standards. DNV GL’s fourth edition of Maritime Forecast to 2050 sets out three decarbonization pathways for shipping and explores detailed energy mix and fleet composition scenarios. Plus it aims to assist shipowners in choosing the right fuel and technology options for next-generation ships and sets out three decarbonization pathways for shipping and also explores detailed energy mix and fleet composition scenarios, based on different energy prices, demand growth and regulatory options.

The findings all help to pick the right fuel solution for future-proofed vessels and scenario modelling showing possible decarbonization pathways.


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Hydrogen To Deeply Decarbonize Oil and Gas Industry From Mid-2030s

New research from DNV GL
forecasts that hydrogen will be a catalyst for deeply decarbonizing the oil and gas value chain, transforming the oil and gas industry in the process, but it won’t begin to scale as an energy carrier until the mid-2030s.

Explore the outlook for hydrogen and for decarbonizing the oil and gas industry in DNV GL’s dedicated Energy Transition Outlook report for the industry providing an independent forecast of developments in the world’s energy system to 2050.

Furthermore, get insights into the multiple energy transitions taking place around the world, as energy demand slows, oil demand never again reaches the levels of 2019, and natural gas becomes the world’s largest energy source.


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Equinor Collaborates with Microsoft on Northern Lights Carbon Capture and Storage Value Chain

Equinor has signed a Memorandum of Understanding (MoU) with Microsoft to explore ways to support the Northern Lights carbon capture and storage (CCS) project as a technology partner. Microsoft will explore using the project to enable the transportation and storage of captured CO2 . Equinor is developing the project together with Shell and Total as equal partners.

“Carbon capture and storage is a proven technology and has the potential to play a key role in decarbonizing energy and industries across sectors to meet international climate targets,” said Equinor Executive Vice President Irene Rummelhoff. “We look forward to working together with Microsoft and the Northern Lights partners to develop digital technologies for Northern Lights. We are also happy to partner with Microsoft to explore opportunities for the Northern Light project to remove carbon from Microsoft’s operations.”

“One of the world’s imperatives is the need to develop new ways to capture, transport, and permanently store carbon. This will require enormous investment and innovation, including a huge amount of computing power and data,” said Brad Smith, president of Microsoft. “As a company, Microsoft is excited about and committed to supporting promising carbon capture approaches. Our goal is not only to contribute our technology and know-how, but explore how new solutions like the Northern Lights project can help us meet our own carbon negative goals by 2030.”

Irene Rummelhoff, Equinor’s executive vice president for Marketing, Midstream and Processing (MMP), and Brad Smith, president of Microsoft. (Photo: Ole Jørgen Bratland)

Equinor and Microsoft have agreed to:

  • Explore a technology collaboration to integrate Microsoft’s digital expertise into the Northern Lights project.
  • Microsoft will explore the use of Northern Lights’ CO2 transport and storage facility as part of Microsoft’s portfolio of carbon capture, transportation, and storage projects.
  • Explore ways for Microsoft to invest in the effective development of Northern Lights.
  • Explore and establish advocacy of policies that help accelerate the contribution CCS can make to meeting Europe’s climate goals.

“Together with the other Northern Lights partners, we will explore how this carbon capture and storage project can help potential future customers to mitigate emissions caused by their own energy use. This relationship will make decarbonization solutions including carbon capture and storage technology available to increasing numbers of customers,” says Syrie Crouch, Vice President for CCUS in Shell.

Prime Minister Erna Solberg at the signing ceremony for the MoU. (Photo: Ole Jørgen Bratland)

“As an historic CCS partner of Norway since 1996, Total is proud that its renewed commitment with Northern Lights project enables this new cooperation with Microsoft. Northern Lights and its partners are at the fore front of offering innovative services to the industry worldwide. We believe that this will be the start of a fruitful collaboration in line with our ambition to get to net zero by 2050.’’ says Gabrielle Gauthey, Senior Vice President Carbon Neutrality Businesses at Total.

Equinor, Shell and Total made a conditional investment decision on the Northern Lights CO2 transport and storage project in May 2020. Pending approval by regulatory authorities, the project partners will form a joint venture. It will be responsible for creating an open-source, ship-based carbon transport and storage network including developing business models to store captured CO2 from across Europe. The final investment decision is subject to the Norwegian parliament’s approval, anticipated late 2020. The plan is to start operations in the first half of 2024.

MoUs have been signed with eight European entities representing different industries, including Air Liquide, Arcelor Mittal, Ervia, Fortum Oyj, HeidelbergCement AG, Preem, Stockholm Exergi and ETH Zürich. As part of the MoUs, the parties are looking at solutions for CO₂ delivery, transport and storage of CO2, including logistics, CO2 specifications and roadmap towards potential start of operations.

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Bulk, Cruise & Ro-Ro Operators get Wilhelmsen’s Digital Mooring System

The Maritime Executive’s latest news– offering consistently faster, more efficient, and safer mooring, Synergy Ocean, Viking Cruises, Berge Bulk and Finnlines have all signed up to be first to utilize Wilhelmsen’s one of a kind digital mooring system aboard their vessels.

Developed and refined over the past three years, Wilhelmsen’s Smart Ropes system is poised to dramatically improve mooring safety onboard vessels. Based on the experience from rigorous testing aboard a working ro-ro vessel, all parts of the system have been refined and improved in readiness for the next phase of installations.

Comprising a patent-pending measuring unit, embedded within the mooring rope, the ‘smart’ unit transmits key tension, time, temperature data in addition to a combination of parameters that make up the proprietary system design. Using the latest wireless communication, the data is sent to a command module located on the bridge, designed to work even under the most challenging mooring conditions typically experienced in poor weather. This data is processed and transferred to a live feed, running on a tablet, or computer on the ship’s bridge, backed-up in the cloud.

Helping to ensure mooring ropes have the right tension, in the right place, at the right time, all the time, Wilhelmsen’s unique system, has been specifically developed in order to relegate over tensioned lines, premature wear of ropes and in the worst-case scenario unexpected rope failures, to history.

Magnus Dickens, Venture Lead in Wilhelmsen Marine Products’ recently established Open Innovation function, says, “This isn’t a gimmick or another piece of badly thought out maritime bloatware. We have spent years developing a completely new technology, which brings accuracy, transparency and consistency to a task which is currently haphazard and fraught with risk. We are thrilled to partner up with these four, forward-learning companies who share our vision of safer, more effective, data-driven mooring operations”.

Capt. Shivram Volety, Director of Synergy Ocean Maritime Inc. says, “Seeing the tension of a vessel’s mooring ropes for the first time, in real time, via an app is a novelty. But it absolutely shouldn’t be, it should be necessity. Wilhelmsen are determined to push the boundaries and we Synergy Ocean Maritime Inc., are proud to be one of the first companies to be able to benefit from their Smart Ropes system”.

He adds, “Safety is at the forefront of our operations, at sea and in port and we are always looking for new systems, products, and processes that can further improve how we work. At Synergy Ocean we are wholeheartedly committed to technology-enabled ship management for safer and efficient ship operations. That is why we are keen to explore and analyse Wilhelmsen’s Smart Ropes mooring system and want to be one of the first companies to have the system installed. It has the potential to totally revolutionize vessel mooring, making our port calls quicker, more efficient and most importantly safer”.

The first installations of the system will begin in Q3, with 4 vessels using SmartRopes onboard. The 4 vessels represent very different vessel segments with unique challenges, and Wilhelmsen will work closely with the customers to solve any specific pain points.

Utilizing the latest wireless protocols optimized for low battery usage, the sensor, its outer casing and the command module elements have all been improved over several iterations, in collaboration with engineering partner Hugg. Housed in a cigar-shaped, heavy duty metal baton, the final version of the sensor and battery unit weighs just under 1kg and has no influence or impact on the handling of the ropes it sits within.

Capturing live load distribution data, the system provides vessels complete transparency when it comes to rope tension, with the bridge able to see the tension in each of their mooring lines, via a dedicated app which runs on a tablet or laptop.

In addition, this data will prove invaluable as Wilhelmsen looks to further push the boundaries of rope technology by subscribing to a ‘Safe by Design’ philosophy encompassed within its wider Timm Ropes portfolio.

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Aussie Company ‘Great Southern Technologies’ Shining Example of Successful Licence Agreement with Norway’s Waste to Energy (WtE) Dynamo ‘Energos Technology AS’

We often don’t hear about those Australian companies that have successfully negotiated Licence Agreements with Norwegian companies. But one shining example is that of Australia’s Great Southern Technologies (GSWT) and Norways’s Energos Technology AS.

Our member, Great Southern Waste Technologies (GSWT), is an Australian company, co-owned and co-founded by its Managing Director, Mr Craig Gilbert and supported by GSWT CFO Mr Bill Keating, who successfully negotiated a Licence Agreement with Norwegian based Waste to Energy (WtE) technology supplier Energos Technology AS, to exclusively deploy this proven technology in Australia.

 The Energos patented technology has extensive and well proven history in operations, and most importantly, functions exceptionally well and far below all prescribed limits for emissions under current EU Emissions Directives, those emissions limit’s similarly adopted by Australian Environmental Protection Agencies.

Currently, GSWT has a site nominated in Dandenong Victoria, for the first planned development of the Energos WtE to thermally treat ~ 100,000 tonnes per annum of household/commercial & industrial wastes and is well advanced in various stages of development.  And their Dandenong project has now received Planning Approval from Local Council.

Environmental Works Approval from Victoria EPA has been granted, however it remains the subject of a VCAT review, brought about by Local Council. GSWT are confident that the Environmental Approval progressed by the Vic EPA (as issued) was stringently assessed from various but not limited pathways such as Environmental, Science, Chemistry, Emissions & Human Health.

To find out more, take a look at the full copy of the Environmental Approval accessed here as well as the summary document.

Although various concerns have been raised by community groups, as WtE is generally a new concept in Australia, it is not an incinerator, but rather a two stage gasification process.

Craig and his team are making sure that extensive Stakeholder and Community engagement are ongoing and will continue.

Waste to Energy must principally align with Victoria’s Circular Economy Policy objectives, and as such, does not seek or desire, to undermine Recycling practices. WtE, quite simply, is a finishing process to deal in a more environmentally effective manner with residual wastes from households and specific industries, to extract the embedded energy that would be otherwise entombed if not lost in landfill forever.

The centralized model contemplated, allows for a “region” to manage its own wastes, and not rely on heavy vehicle transport crisscrossing one side of the metropolis to the other, as landfill in the South East of Melbourne, will likely be redundant by 2025/6, meaning a proportion of waste from the south east, will likely need to be transported to landfills in the west or north.

The Dandenong project has capacity to generate electricity to power equivalent of around 7000 homes, and provide a net GHG benefit around 142,800 t CO2e.

GSWT is also now advancing its focus on residual wastes from Resource Recovery and Recycling streams, as there will always be a residual, and WtE can deal with this residual.  Waste to Product is also being looked at and how this can invigorate the manufacturing industry to develop useable products for markets and industry.

Further links and videos of interest:


About Craig Gilbert:

  • Commercial & Industrial Property Development
  • Manager for Project delivery from greenfield to finished product
  • Expanded into Civil Project Construction and land remediation
  • Commenced looking at environmentally alternative solutions to Waste (generally) in 2014
  • Currently driving the GSWT team for Waste to Energy Project in Dandenong
  • Vision to look for solutions to align with Circular Economy outcomes and how this can integrate to assist in invigorating Manufacturing in Victoria/Australia.


Stay tuned for further updates from Craig and his team as this innovative waste project gathers momentum and traction.



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Construction Starts On The World’s Largest Floating Offshore Wind Farm

EQUINOR’s Latest News profiles Norway’s Prime Minister Erna Solberg and Kværner Apprentice, Arne Linga, starting construction of Hywind Tampen, a floating offshore wind farm technology project, at Kværner Stord, opening up new opportunities for Norwegian industry.

Photo: Øyvind Gravås – WoldCam / Equinor ASA)

Prime Minister Solberg and Mr Linga started the ‘cutting robot’ on the project’s first sheet of steel on Thursday, 1 October. Kværner’s assignment will include building 11 floating concrete hulls for the turbines on Hywind Tampen.

Hywind Tampen is a new chapter in Norway’s narrative as an energy nation. With support from the Norwegian authorities, we’re not only building Norway’s first offshore wind project; we’re refining floating offshore wind technology along with the Norwegian supplier industry,” says Equinor president and CEO Eldar Sætre.

“Eighty percent of the world’s offshore wind resources are located in deep water areas and are available for floating offshore wind projects. If we can use projects like Hywind Tampen to make floating offshore wind competitive with other forms of energy, the technology will be able to deliver large-scale renewable power and contribute to a more sustainable global energy supply. A floating offshore wind market will also open up considerable industrial opportunities for Norwegian industry,” Sætre says.

The development of the Hywind Tampen project involves around 250 full-time equivalents for Kværner employees. Kværner’s project will also generate around 800 full-time equivalents in ripple effects for suppliers and the public sector, among others.

Photo: CEO CEO Eldar Sætre at Kværner Stord. (Photo: Øyvind Gravås – WoldCam / Equinor ASA)

A study conducted by Multiconsult shows that, in total, the Hywind Tampen project could provide 1,550 to 3,000 full-time equivalents in ripple effects for the Norwegian private sector.

Equinor’s ambition is for floating offshore wind to be competitive with other forms of energy by 2030.

“By using larger turbines, concrete substructures, new technology and a new assembly method, we’re well on our way toward delivering on the objective to reduce costs by more than 40% compared with Hywind Scotland. This is an important step to establish floating wind as a sustainable power supply alternative,” says Hywind Tampen project director Olav-Bernt Haga.

“If more major floating offshore wind projects are realised in the future, it will be possible to reduce costs even further, and we could see a development in cost reductions equivalent to the one we’ve seen in fixed foundation offshore wind,” Haga says.

Equinor sees a potential for floating offshore wind projects in Norway, the UK, Europe, the US and Asia.

The Hywind Tampen project will be the first floating offshore wind project to supply renewable power for oil and gas installations. The wind farm will have a total capacity of 88 MW, and is expected to cover about 35 percent of the annual power needs on the five platforms Snorre A and B and Gullfaks A, B and C.

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Solved! Takeaways from Last Weeks Discussion with Andrew Wear


What is Australia good at:

  • Immigration: resulting in one of the biggest world economies
  • Inequality in carbon emissions and renewables



What are the Nordics good at and what Australia can learn from Norway and its’ neighbours:

  • Low social economic inequality and greater income. High income = low inequality
  • Above average in equality and incomes
  • Norway has a strong democracy and is one of the happiest countries in the world
  • Norway has high economic participation and social inclusion
  • Norwegians work 6.5 weeks less that Australians + have one of the lowest working hours in the world, resulting in greater labour productivity since Norwegians/Nordics work less and are well rested compared to Australia and the rest of the world
  • Denmark’s Samu Island has a farming community of 4,000 and is Denmark’s renewable energy island, providing a good example of how a farming community revitalised itself by investing in and owning the wind turbines. Their ownership of the turbines resulted in minimised opposition. Even as a nation producer of pig manure, Denmark as a whole halved its per capita carbon emissions compared with Australia who had increased theirs.
  • Their economies have increased and grown as carbon emissions declined
  • Gender equality in Iceland is one of the highest globally with Norway placed in the Top 3:
    • 1st Iceland
    • 2nd Norway
    • 3rd Finland + Sweden
  • Nordics countries are also very good at female workforce participation, with Iceland leading the way with no gender pay gap
  • Germany’s success has been driven and achieved by medium sized businesses supporting innovation + unique areas of production and ‘narrow niches’ such as in manufacturing and how to build innovative ecosystems in their cities
  • Unique historical and political environments leading to quotas on Boards of Listed Companies to include women which is not the case in Australia. Could this be due to the fact that this too culturally embedded and is not transferable to Australia? Plus, the Nordic’s 50% representation of women on public Board of companies leads us to reflect that this may not be possible in Australia due to these cultural manifestations.
  • Australia is stuck and can’t see its way out when it comes to Energy and Climate and will need a to use a ‘circuit breaker’ to help see our way out.


Andrew Also Raised our Awareness To Consider:

  • No country is perfect and even Norway has issues grappling with oil and gas and how our reliance on this energy source can be reduced.
  • All countries are in a conundrum but they need to have an open mind and how they can innovate. Singapore provides inspiration in another key element: Education. 10 years ago Finland was leading the world in this domain. Today it is Singapore; a reminder that we also need to keep any eye on who is achieving which comes with a different mindset and how to allocate privilege.


Key Questions Raised:

  • How can we apply these lessons raised by Andrew in ‘Solved! How other countries have cracked the world’s biggest problems and we can too!’?
  • Andrew’s observation is that the current recession resulting from Covid-19 will be with us for a long time and that the Australian Government will play a role for considerable period ahead as the economy will need physical stimulus. At the same time, the government can reconfigure and learn. While the debates are around infrastructure delivery they actually should be on service sectors, such as hospitality, with lots of conversations for reshaping companies and not ‘business as usual’ as Andrew sees that this is a great opportunity for businesses to make change.
  • Renewables, according to Andrew, will be a way to stimulate economies and this is where Australia can learn from the Denmark and the Nordics in this recovery period.
  • Studies and research were also cited as one domino that can provide inspiration to do and get the ball rolling.
  • Inequality: cited as critical and very bad for economic growth and that labour participation is vital. It can be addressed through more equity in education and the labour market which would put Australia in good stead if it can overcome gender and labour inequality.
  • Andrew emphasised that how we address inequality during this period is key as well as learning from Norway and its Nordic neighbours.
  • According to the IMF, tax cuts in Australia will not and cannot provide growth but Andrew remains confident that we ‘tick all the boxes’ and like the Nordics we have good robust economics and the institutional architecture to move through weighty problems. And that solutions do exist!
  • What can Nordic/Northern European countries work on: according to Andrew there are a couple of areas, with carbon emissions reductions being one and innovation being the other. According to Andrew, on a competitive scale, Nordic countries are not quite as innovative as Australia. Which poses the question, where would Norway be without oil? Denmark not too far behind in those metrics although it doesn’t have oil. But all are in the same realm of statistics so can no longer put success down to oil



And as a final takeaway, the upside of both Nordic countries and Australia: crime rates are low compared to other European countries such as Germany and the UK. And their smaller populations encourage and enable change and for decisions to be made faster and more easily. And this where both Norway and Australia can make headway in these months and years ahead.

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Changes to tax residency ideally involve careful planning however at the height of the global pandemic, many Australian expatriates working overseas had no option but to promptly return to Australia with little thought given to the possible tax implications of their return.  In addition, many foreign expatriates found themselves stranded in Australia.

Six months down the track, with travel restrictions largely still in place, this group of individuals may be running the risk of becoming accidental Australian tax residents.  Changes to tax residency can have some significant implications and this brief seeks to highlight some of the key areas for consideration for both individuals and employers.

When am I an Australian tax resident?

Determining tax residency will always be a question of fact and must be considered for each income year ending 30 June, based on an individual’s circumstances.  Broadly, there are three main tests of tax residency in Australia, being:

The Resides Test


When considering the relevant circumstances and facts, does the individual ordinarily reside in Australia.  Relevant factors include:


·       Behaviour while in Australia:

–        Intention or purpose of presence

–        Family and business/employment ties

–        Maintenance and location of assets

–        Social and living arrangements.

·       The period of physical presence in Australia:

–        Degree of continuity of the stay

–        Habit

–        Routine


The Domicile Test


Is the individual’s domicile in Australia?  This can be a person’s domicile of origin or domicile of choice.

An exception to this test is where the individual has a permanent place of abode overseas.


The 183 Day Test


Has the individual been physically present in Australia for 183 days or more in an income year ending 30 June?

An exception to this test is where the individual’s usual place of abode is overseas, and the individual has no intention to take up residence in Australia.



In assessing the above tests, an individual’s intention regarding remaining in Australia temporarily or otherwise is an important factor to not only consider, but also to support a position as the Australian Taxation Office (ATO) often has the benefit of hindsight when reviewing tax residency matters.

Testing residency in the era of COVID

Foreign expats in Australia

The inability to depart Australia during COVID-19 has generated uncertainty for many regarding their tax residency status in Australia.  In response, the ATO has released limited guidance that provides that a foreign resident will not become an Australian resident where they are stranded here temporarily (i.e. for weeks or months) due to COVID-19, if they usually live overseas permanently and importantly, they intend to return overseas as soon as they are able.

However, the longer the crisis continues and the longer the individual stays in Australia, the less likely that the ATO will consider their stay to be temporary, particularly given that whilst travel bans are in place, individuals are mostly free to return to their home countries.

TIP: Where foreign expats have entered Australia on a temporary visa, they may be considered to be a temporary resident for Australian tax purposes where certain conditions are satisfied. The taxation rules for temporary residents are more concessional than those set out below.

Australian expats returning

Returning Australian expats may find that proving their stay in Australia is temporary is especially difficult, given the likelihood that they will have existing social and family links to Australia and may have retained some Australian assets, including a home.

Given the subjective nature of tax residency and the importance of demonstrating an individual’s intention, individuals must be aware that there may be a tipping point in which their intention to return overseas is at odds with their actions.  For example, the following factors may be indicative of a change in a person’s intention to remain in Australia for the short to medium term:

  • Making Australian living arrangements more permanent (i.e. signing a 6 or 12-month rental lease or buying a family home), especially when coupled with giving up an overseas residence. This would likely mean that an individual would no longer have a permanent place of abode overseas.
  • Enrolling children in local schools
  • Joining Australian clubs (and cancelling foreign memberships)
  • Foreign employment ending (i.e. through resignation or termination)
  • Opening Australian bank accounts (and closing foreign ones).

Happy new year – are you a resident?

Given that we have now crossed over in to the 2021 financial year, the 183-day test becomes increasingly important, particularly given recent case law (FCT v Addy) regarding this test.  Judgments from the case are suggestive that even if an individual is living in Australia on a temporary basis and intends to return to their home country, they may be considered to be an Australian resident where they are still in Australia on 1 January 2021 (on the basis that their stay in Australia would exceed 183 days in an income year).

TIP: Those individuals that find themselves in this scenario, are encouraged to seek tax advice and consider raising the matter with the ATO, to ensure the ATO can be satisfied as to the individual’s usual place of abode being overseas and the intention to reside overseas.. It is important that individual’s robustly document their circumstances, including that they have maintained a home overseas, still have foreign employment and importantly are able demonstrate their intention to return overseas.

You’re a resident – so what?

Australian tax residency comes with the requirement to lodge an Australian tax return and pay Australian tax (and likely the Medicare Levy and surcharge, depending on whether exemptions apply) on income from worldwide sources.  Further, of particular concern for the accidental tax resident is Australia’s deemed acquisition and disposal rules for assets which are subject to the capital gains tax rules.

Under these rules, an individual who becomes an Australian tax resident (other than a temporary resident) is deemed to have acquired all their assets other than taxable Australian property (e.g. shares, foreign property, term deposits, interests in other entities, foreign currency deposits) for their market value at the time they became an Australian tax resident.

Establishing the date of residency will therefore be a critical factor and depending on the particular asset’s market value, the resetting of an asset’s cost base to market value could have varied results, which may or may not be advantageous to the individual.

Should an individual ultimately leave Australia and cease to be an Australian tax resident ( i.e. where travel restrictions are eased), they will be deemed to have disposed of all assets other than taxable Australian property for the asset’s market value at the date they cease being an Australian tax resident. The likelihood of being taxed on an asset that has not been disposed of and to which no proceeds have been received, can be a significant concern for affected individuals.

It is also noted that the CGT discount will not be available if a foreign asset is sold (or deemed to be sold) within 12 months of the individual becoming a resident.

NOTE:  Individuals can elect to disregard a deemed disposal, however where an election is made, the assets are effectively taken to be Australian assets that will be subject to Australian capital gains tax when the asset is actually sold.

TIP: Where an individual is considered a resident of both Australia and another country and Australia has a Double Tax Agreement (DTA) with the other country (i.e. such as Norway), the DTA should be considered to determine which country has taxing rights for income and gains and whether there is relief from double taxation.

TIP: A credit for tax paid overseas on foreign source income may be available in Australia to offset Australian tax payable. This may also depend on the terms of the relevant DTA Australia may have with the foreign country.

Other tax implications

Where a foreign resident becomes an Australian tax resident, the following non-exhaustive tax implications may also occur:

  • Foreign employment income will be taxed at Australian tax rates when received, regardless of whether it was in respect of work performed prior to the change in residency.
  • The impact of COVID and accidental Australian residency may have the unwelcome effect of dual residency – i.e. where two jurisdictions consider an individual to be a tax resident and tax them accordingly. Relief from double taxation may be available where a DTA between the jurisdictions exists.
  • Foreign companies owned and controlled by a now Australian resident may also be subject to a tax residency change and further tax implications.
  • Withholding tax obligations may exist in respect of interest payable on foreign loans.
  • The tax implications of foreign exchange fluctuations must be considered in respect of foreign currency.
  • Interests in foreign companies and trusts must be considered as Australia has complex rules regarding such interests. Income derived by such entities can be taxable to individuals in Australia even though no actual distribution of income is made to the individual.
  • Individuals that decide to stay in Australia permanently may wish to consider the transfer of their foreign pensions to Australia. Where such a transfer is being contemplated, it is strongly advised that tax advice be sought prior to any transfer, as there are a number of considerations and getting it wrong may have significant adverse tax implications.


Still a foreign resident ..?

Expatriate employment income

Ordinarily, and subject to any relevant DTA, foreign residents will only be taxed on Australian source income.  This may include employment income earned whilst being stranded in Australia.

For those foreign residents who have received paid leave while in Australia and for those non-residents that have earned salary and wages from short term (i.e. less than 3 months) remote working arrangements, employment income will not be taxable in Australia.

Furthermore, those non-residents whose working arrangements in Australia have or will continue for longer than three months, careful consideration should be given to employment terms and other matters, including their intention to leave or stay in Australia, when contemplating whether Australian tax will be imposed.

In limited circumstances, employment income will not be deemed to have an Australian source (and will not be subject to Australian tax) where a non-resident, who due to COVID, has had to work from Australia but intends to leave Australia as soon as they are able to and has no other connections here.

Employer obligations

The ATO have advised that from 1 July 2020, foreign resident employers must withhold PAYG for any:

  • Australian resident employees; and
  • foreign resident employees whose employment income is Australian sourced income.

Exceptions may apply for foreign resident employees for whom a DTA exception applies, which may broadly allow foreign residents to earn Australian sourced employment income for a short period (usually 183 days in an income year) free from Australian tax.

Superannuation Guarantee (SG) contributions, fringe benefits tax and payroll tax obligations also need to be considered as these obligations are separate from rules relating to the taxation of employment income.

TIP: Employers with displaced foreign employees will need to re-assess any tax compliance obligations that may now exist post 1 July 2020 and take steps to manage these obligations.  Importantly, employers should continue to make enquiries as to the residency status of any employees as this may have changed.

Key Takeaways


  1. Confirm the conditions and time periods of the relevant DTA (if any) for any short-term tax exemptions on Australian employment obligations.
  2. Check in with employees and understand their circumstances and intentions around staying in Australia. It is important to remember that despite any relief available, employers must withhold if they believe at the time that employment income is paid, based on the facts and circumstances of that employee is likely to remain in Australia for more than the applicable time period.
  3. While exemptions for PAYG withholding may apply- other employment obligations (i.e. SG) may still apply.


  1. Confirm the conditions and time periods of the relevant DTA (if any)- particularly in light of the 183-day test.
  2. Remember an intention to live overseas needs to marry up with actions and behaviour.
  3. If uncertainty exists – seek tax advice and consider early engagement with the ATO.
  4. Where individuals plan to return to their overseas lives, it is strongly advised that they document and demonstrate their overseas ties and their intention to return.
  5. Where Australian residency is likely, the date of residency change and the tax implications must be carefully considered and documented.

This information is current as of 18 September 2020, however, please note that announcements and changes are being made by the Government and the ATO regularly, and we expect that the tax and business-related responses will continue to evolve.

If you would like to discuss any matters in this newsletter in further detail, please do not hesitate to contact either Rachel Pritchard or Robyn Dyson of Cooper Partners on 08 6311 6900.

This information is general advice only and neither purports, nor is intended to be advice on any particular matter.
No responsibility can be accepted for those who act on the contents of this publication without first contacting us and obtaining specific advice.
Liability limited by a scheme approved under Professional Standards Legislation.
For further information please refer to our privacy policy.


                           Robyn Dyson, Senior Manager                                                                                                   Rachel Pritchard, Principal, Leader in Human Capital

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Norway’s official marketplace platform for green technology – The Explorer – a free matchmaking service for connecting global challenges with green solutions – funded by the Ministry of Climate and supported by Norway’s largest private companies together with Innovation Norway profiles Cinderella Eco Incineration Toilets at the forefront of this green revolution.

*Photo above shows a Cinderella a technology meeting with (from left) Mari Lise Andersen Sunde, SCM consultant, Gunhild Sjøvik, CEO and Bård Olav Sugustad, CTO

The Explorer portal promotes green technology from Norway to the world. Here you can read short texts about some of the most exciting green solutions on offer from leading Norwegian companies. These are distributed to a large and targeted international audience through digital channels, events, embassies and more.

An important requirement for companies is that they meet one or more of the UN’s Sustainable Development Goals (SDG’s)
With our water-free toilets, Cinderella Eco Group is particularly involved in meeting the goals of SDG number 6: Clean water and sanitation for all by 2030. We mark the UN’s World Water Day every year on March 22 and UN World Toilet Day on November 19. Both these dates are important to us, highlighting the fact that over half of the world’s population, 4,2 billion people, still lack safe toilets.

In addition, SDG number 3, Good Health, is of crucial importance to us. Our solutions ensure pathogen-free waste, free of all harmful bacteria, which prevents the transmission of infections and diseases in water and soils that cause high mortality. Every year, we mark World Health Day on April 7.

Proud to be listed among leading green innovators
The Explorer contributes to promote Norwegian exports and value creation and Cinderella is proud to be in such celebrated company with some of the country’s most innovative environmentally conscious contributors. See the link to the presentation of Cinderella Eco Group in the portal here. Be sure to click on the film to see more.

Continuously developing our CSR strategies
As a sustainably managed company, located in a small island community in the heart of the Norwegian fjords on the mid-western coast, Cinderella Eco Group is part of a family owned company in its fourth generation. CEO Gunhild Sjøvik is dedicated to bringing grounded, local family values into every part of the company’s value chain. This means a continuous focus on developing responsible management and respecting those resources we are given and those we create.

When nature calls, is a payoff Cinderella uses to bring a smile to the obvious, but it also imparts a deeper meaning: respecting our planet and each other in the best way we can.


Credits -Text: Trude B-J Margel – Photo: Tingh Kommunikasjon, Molde

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Meet Our Members

New Young Professional Member Anastasia Serafimovska is a researcher with first class psychology honours and a strong background in neuroscience and pharmacology.

At the University of Sydney, Anastasia is involved in developing and evaluating data-driven decision-making tools spanning psycho-oncology to addiction contexts.

She is a strong advocate for collaboratively channelling the strengths of academia and industry to culminate in lasting societal and economic benefits. By joining the Norwegian Chamber, Anastasia is keen to meet like-minded people over akvavit and explore how her interests in mental health, predictive analyses and mathematically modelling big data can support members and industry.

To find out more, you can connect with Anastasia via her LinkedIn profile.


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