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 (8)
(8)
With reference to subparagraph f) of paragraph 2 of Article 6 (Income from Real Property) of the Convention:
(a) rights to receive payments where the person receiving the payments grants rights to explore for or exploit natural resources; and
(b) rights to receive payments which arise or are quantified by reference to the exploitation of, or exploration for, natural resources in circumstances where the person receiving the payments may not have an interest in the natural resources or rights over the extraction of, or exploration for, natural resources.
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 f) of paragraph 2 of Article 6 (Income from Real Property) of the Convention:
It is understood that the rights referred to in that subparagraph principally cover:
(a) rights to receive payments where the person receiving the payments grants rights to explore for or exploit natural resources; and
(b) rights to receive payments which arise or are quantified by reference to the exploitation of, or exploration for, natural resources in circumstances where the person receiving the payments may not have an interest in the natural resources or rights over the extraction of, or exploration for, natural resources.
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