Explanatory Memorandum(Circulated by authority of the Treasurer, the Hon. Frank Crean, M.P.)
The main purpose of this Bill is to give the force of law in Australia to a comprehensive double taxation agreement between Australia and the Federal Republic of Germany that was signed in Melbourne on 24 November 1972.
The Bill specifies that interest and royalties derived from the Federal Republic by residents of Australia, and in respect of which, under the new agreement, the Federal Republic limits its tax to 10 per cent, will not, by reason of the payment of that limited tax, be exempt from Australian tax. Australia will instead allow credit for the limited tax against the Australian tax on this income.
The Bill also contains amendments of a technical character made necessary by the proposed surcharge of tax that is to be payable for the 1974-75 income year in respect of property income.
Notes on the clauses of the Bill are given below and these are followed by explanations of the articles of the agreement and the paragraphs of the protocol to the agreement.