From williambuck.com: Australia’s PSI legislation treats income earned from personal exertion as equivalent to employment income for tax purposes, preventing doctors and other professionals from splitting this income to reduce tax liability.

Even if operating through a company or trust, the Australian Tax Office (ATO) will attribute income back to the individual performing the work, disregarding attempts to claim tax benefits through income splitting.

Medical professionals can pay associates, like a spouse, for legitimate work performed, but must adhere to market rates, and the payment for superannuation contributions must align with actual work services provided.