Australian Tax Treaties
Japanese Convention
CONVENTION BETWEEN AUSTRALIA AND JAPAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
SECTION (11)
(11)
With reference to subparagraph (a) of paragraph 9 of Article 7 (Business Profits) of the Convention:
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
With reference to subparagraph (a) of paragraph 9 of Article 7 (Business Profits) of the Convention:
It is understood that in the case of Japan the term " a trust which is treated as a company for tax purposes " means a trust, the trustee of which is subject to tax in respect of profits derived from business carried on by the use of trust estate.
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