Explanatory Memorandum(Circulated by authority of the Treasurer, the Hon. P.J. Keating, M.P.)
This Bill will amend the Income Tax (International Agreements) Act 1953 to:
- make clear Australia's right to tax distributions of income derived from business operations carried on in Australia by a trustee of a trust estate where the beneficiary (or unit holder in the case of a unit trust) is a resident of a country with which Australia has concluded a comprehensive taxation agreement. This measure was announced on 19 August 1984, and will guard against revenue losses that could be substantial if a court were to hold that Australia does not have the right to tax the distributions in question; and
- give the force of law in Australia to
- a comprehensive taxation agreement between Australia and Malta which was signed in Malta on 9 May 1984; and
- a protocol amending the existing taxation agreement between Australia and the Kingdom of Belgium which was signed in Canberra on 20 March 1984.
Neither the Maltese agreement nor the Belgian protocol is expected to have any significant effect on revenue.