AUSTRALIAN TAX TREATIES

United Kingdom Convention  

CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL GAINS  

2003 UNITED KINGDOM NOTES

No LGB 03/170  

4.  
With reference to Article 9 (Associated enterprises), the Contracting States note that the expression " dealing wholly independently with one another " is included in paragraph 1 of the Article to conform to Australia ' s consistent treaty practice and to address Australia ' s concerns that the appropriate benchmark for determining the conditions operating between the associated enterprises should have regard to whether those dealings between the enterprises occurred on a truly independent basis.




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