AUSTRALIAN TAX TREATIES
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 Article 12 (Royalties),
the term " royalties " does not include payments for the use of spectrum licenses. The provisions of Article 7 of the Convention shall apply to such payments.