AUSTRALIAN TAX TREATIES
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.
[ ATO Notation: REPLACED by paragraph 1 and subparagraph e) of paragraph 3 of Article 4 of the MLI.] 
Refer to text box immediately after paragraph 4 of Article 4 of the Convention.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.