Hi community,
I noticed a similar question was asked here in October 2024 regarding CFE (Caisse des Français de l’Étranger) contributions and Article 17(4) of the France-Australia Tax Treaty.
My situation is nearly identical:
- French expatriate in Australia (Perth, TSS 482 visa).
- Contributing to CFE since 01/09/2024.
- CFE is managed by CNAV (French social security) and validates pension quarters (I have official attestations).
- I was not an Australian resident before 01/09/2024 and started contributing to CFE immediately before/at the start of my employment in Australia.
Key difference:
- I have official CFE attestations proving the scheme’s recognition in France.
Question:
In the previous thread, the ATO redirected to general super contribution eligibility criteria. However, Article 17(4) seems to provide a specific pathway for foreign pension schemes like CFE.
- Does the ATO accept that CFE meets the conditions of Article 17(4)?
- If not, what additional evidence would be required to demonstrate that CFE is "recognised for tax purposes in France" (Article 17(4)(b)(ii))?
Any clarification would be greatly appreciated!
Note: I’m considering a Private Ruling but wanted to check if there’s been any update since October 2024.
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