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.
Profits of a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. (2)
The provisions of paragraph (1) shall also apply to profits derived from participation in a pool, a joint business or an international operating agency.