• Agreements for the allocation of taxing rights with respect to certain income of individuals

    Australia has tax agreements with other countries to help determine how tax should be paid by people who both:

    • are a resident in one country
    • work temporarily in another.

    These agreements are called:

    DTAs

    Deal with the allocation of the taxing rights of all types of income, profits and gains between Australia and the other country with which we have agreed a DTA.

    TIEAs:

    • improve the exchange of tax information between Australia and other countries
    • promote fairness and enhance Australia's ability to administer and enforce its tax laws.

    ATR agreements:

    • are like a partial tax treaty
    • differ between countries but generally focus on the allocation of each country's right to tax income earned by students, pensioners and government employees who are resident of one country but earning income while temporarily a resident in the other.

    ATR agreements may also contain articles dealing with:

    • mutual agreement procedures (MAPs- Using these procedures, countries can resolve issues that may arise from transfer pricing adjustments. There is a link to more on transfer pricing below.
    • exchange of information for carrying out the provisions of the ATR agreement Unlike the TIEAs, ATR agreements are given force of law in Australia by the International Tax Agreements Act 1953.

    See also:

      Last modified: 03 Nov 2016QC 22192