AUSTRALIAN TAX TREATIES

Japanese Convention  

CONVENTION BETWEEN AUSTRALIA AND JAPAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME  

(4)  
[ ATO Notation: REPLACED by paragraph 1 and subparagraph e) of paragraph 3 of Article 4 of the MLI.] [5]

Refer to text box immediately after paragraph 4 of Article 4 of the Convention.

With reference to paragraph 3 of Article 4 (Resident) of the Convention:

It is understood that the term " any other relevant factors " includes:


(a) where the senior day-to-day management is carried on;


(b) which Contracting State ' s law governs the legal status;


(c) where the accounting records are held; and


(d) where business is carried on.




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