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 subparagraph (a) of paragraph 9 of Article 7 (Business Profits) of the Convention:
It is understood that in the case of Japan the term " a trust which is treated as a company for tax purposes " means a trust, the trustee of which is subject to tax in respect of profits derived from business carried on by the use of trust estate.