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  

7.  
With reference to Article 12 (Royalties), the Contracting States agree that:


(a) the term " royalties " shall not include payments for the use of spectrum licences. The provisions of Article 7 of the Convention shall apply to such payments; and


(b) nothing in the Convention shall have the effect of subjecting to tax in a Contracting State any royalties paid by a resident of that State to a resident of the other State where the payer has outside both Contracting States a permanent establishment in connection with which the liability to pay the royalties was incurred, and the royalties are borne by the permanent establishment.




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