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Question: Robyn Rainer worked as a lecturer with Victoria University in the college of business. The college of business ran a number of courses in Calcutta University, India. An employee of Victoria University was coordinator of the Indian course and was situated in Calcutta. Until November 2016 Jason Holm was the coordinator situated in Calcutta. He resigned from Victoria University in November 2016 and returned to Australia. Expressions of interest were called for from staff in the college of business to be the new Victoria University coordinator in Calcutta. Robyn put in an expression of interest and was successful. She was not married and she saw this as an opportunity to advance her career by acting as coordinator for a number of years. She started this new position on 14 January 2017. The position of coordinator in Calcutta was for as long as Robyn wished to remain in the position or as long as the course was conducted in Calcutta. Victoria University owned a flat in Calcutta for the use of the coordinator whilst in Calcutta. On arrival Robyn established a bank account in India and had half her salary paid into the Indian bank account. The remainder of her income was paid into her Australian bank account for purposes of being able to pay for the mortgage on the flat she owned in Melbourne. She had rented the flat in Melbourne for a period of 12 months.

Can Robyn be taxed on any part of her salary, from Victoria University, in Australia for the 2016/17 tax year and any other years she acts as coordinator in Calcutta. Fully explain your answer. Ignorer the operation of double tax agreements.

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