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 (4)
(4)
With reference to paragraph 3 of Article 4 (Resident) of the Convention:
(a) where the senior day-to-day management is carried on;
(b) which Contracting State ' s law governs the legal status;
(c) where the accounting records are held; and
(d) where business is carried on.
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 paragraph 3 of Article 4 (Resident) of the Convention:
It is understood that the term " any other relevant factors " includes:
(a) where the senior day-to-day management is carried on;
(b) which Contracting State ' s law governs the legal status;
(c) where the accounting records are held; and
(d) where business is carried on.
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