Aussies follow Adrian Portelli to Dubai as ATO tightens tax scrutiny

Billionaire Adrian Portelli says harsh taxes and ATO pressure are driving Australians to Dubai as experts warn relocation does not guarantee tax escape and the ATO pursues overseas residents.

BUSINESS & ECONOMY

9/20/20264 min read

Melbourne-born billionaire Adrian Portelli says Australia is chasing away success and he is not alone as a growing number of entrepreneurs and high-net-worth Australians pack one-way tickets for Dubai and other low-tax havens while the Australian Taxation Office tightens its scrutiny of those who try to leave their tax obligations behind.

Portelli’s rationale for relocating to the Middle East is blunt. He told broadcaster Karl Stefanovic in a new episode of his controversial podcast that he does not trust the Australian government because regulators and the ATO have come down hard on him. “I’ve had regulatory issues to ATO issues and I just can’t handle it,” Portelli said, adding that his accounts were frozen at one point so he could not pay wages, staff or bills.

The 34-year-old made headlines in August when he announced to his more than 1 million social media followers that he was moving to Dubai in response to the 2026 federal budget’s sweeping changes to capital gains and property taxes, which critics warn will stifle innovation and punish young entrepreneurs. His subscription-based lottery business, which recently expanded into petrol stations, earned him an estimated $1.44 billion fortune according to the Australian Financial Review’s Rich List, and the federal government had unveiled legislation to outlaw his business model before his departure.

Portelli is not the only one looking overseas. Melbourne lawyer Victoria Wells, who founded her firm Ape Law in the United Arab Emirates in 2022, says she is seeing a surge in Australians – particularly in tech and crypto – seeking to shift their lives and businesses abroad. Last month Wells and her partner Stephan Roberto, along with Bali-based influencer couple Matt Cameron and Felicity Morgan, launched “Project Get Out” to advise Australian founders, investors and high-net-worth families on relocation and tax residency. They received 1,000 inquiries shortly after launching, just as Portelli’s move went viral, and Wells now clocks about 200 inquiries a day.

About 25,000 Australians live and work in Dubai, where expats make up roughly 88 per cent of the UAE’s 11 million population. Dubai has been competing with Singapore and Bali to entice expats, offering a corporate income tax rate of 9 per cent and no personal income tax, compared with Australia’s minimum 25 per cent corporate rate and top personal income tax rate of 45 per cent.

But experts warn that relocating does not automatically mean escaping Australian tax. Deakin Business School lecturer Dr Kerui Zhai says higher personal income taxes and capital gains tax changes are incentives for entrepreneurs to move to the UAE for significant tax savings, but companies with income largely derived from Australia will probably still be subject to Australian corporate tax.

University of Melbourne Law School professor Sunita Jogarajan, who has worked in tax for more than 20 years, says tribunal records show the ATO has been pursuing Australians living overseas who are deemed tax residents to pay their share regardless of where they are. “Foreign residents are taxed in Australia on any money they make in Australia,” Jogarajan said, adding that people need proper legal advice on how their business is structured.

Tribunal cases illustrate the complexity. Engineer Trong Quy sought a refund of $524,943.29 from the ATO for 2016 to 2020, claiming Dubai was his primary residence, but lost his final bid when the tribunal ruled he remained an Australian resident because his family home was in Perth, his wife and daughters lived there, and he kept personal belongings including winter clothing and two guitars he was restoring in Australia. In contrast, oil and gas executive Ragnar Bulie won against the ATO earlier this year after it sought to tax his Singapore income between 2018 and 2022. The tribunal found Bulie’s economic and personal relations to Singapore were stronger than to Australia during that period, even though his wife and children resided in Australia and he owned property here.

Jogarajan says one of the big issues is whether families move together. “You really need to move and have a home overseas and not have those connections to Australia,” she said. “One of the big issues is if the family doesn’t move. The individual might be in Australia for a short number of days, say 30 or 60 days, and not typically be considered a resident here, if their family and children are still here.”

Wells emphasises that Project Get Out is not about engineering arrangements to avoid Australian tax. “Tax is legitimately one consideration in that decision, alongside lifestyle, family, business opportunity, regulation and access to markets – but it shouldn’t be the decision itself. I often say that tax should be one coordinate on the map, not the compass,” she said. She contemplated her own exit years ago after the 2022 crypto crash and news that crypto would no longer be treated as foreign currency and would be hit with capital gains tax in Australia. “That was really the writing on the wall for me. My friends and my peers were leaving. I was like, OK, I have to figure this out. Are there going to be jobs in crypto in Australia? No. Are there going to be clients in crypto in Australia? No, they are also leaving,” Wells said.

Portelli did not respond to a request for comment, but his message to other wealthy and talented Australians is clear. “They are chasing young entrepreneurs, very talented Australians. People of wealth and success are moving. They are fleeing,” he told Stefanovic.

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