The Australian Taxation Office (ATO) issued Interpretative Decision ID 2006/160 explaining the taxation of Australian residents who perform independent personal services for an Italian entity. The ATO concluded that income from such services can only be taxed in Australia, provided that the Australian resident does not have a fixed base in Italy.

The independent personal services were those of a freelance journalist reporting news from Australia to a radio station in Italy without any employment contract with the radio station.

In reaching this conclusion, the ATO considered Arts. 14 (Independent personal services) and 15 (Dependent personal services) of the Australia-Italy tax treaty and the domestic tax law definition of "income from personal exertion", and found that the income should be taxed under Art. 14, which allocates sole taxing rights to Australia.