Australian Tax Treaties

Israeli Convention  

CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE STATE OF ISRAEL FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE  

SECTION 4.  

4.    
With reference to paragraphs 1 and 3 of Article 9 (Associated enterprises) of the Convention:

The Contracting States note that the expression " dealing wholly independently with one another " is included to conform to Australia ' s consistent treaty practice and to address Australia ' s concerns that the appropriate benchmark for determining the conditions that exist, or are made or imposed, between the associated enterprises should have regard to whether those dealings between the enterprises occurred on a truly independent basis.