Conoy 2018, a government department entered into a contract with Consultant Co Pty Ltd for the provision of services by Robert Black, an technician who is nominated in the contract.

The contract specifies that Robert Is required to develop a product for use in the department's IT system in accordance with functionali specifications provided by the department. The contract specifies a fixed amount by way of payment to Consultant Co for the development of the product that is required to be produced within 12months of commencement of the contract. The contract is for the performance of a specific task that produces an outcome or result, with Robert maintaining a high level of discretion and flexibility as to how the work ought to be performed. Payment is not made until the work is performed, although installments are payable upon the achievement of particular milestones. Discuss the tax implications of the personal services income (PSI) legislation to the above arrangement, (500 words)