AUSTRALIAN TAX TREATIES

Israeli Convention  

CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE STATE OF ISRAEL FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE  

13.  

The Contracting States note that departures from the Model Tax Convention on Income and Capital were included in the following provisions of the Convention to conform to Australia ' s consistent treaty practice:



a) Subparagraph b) of paragraph 8 of Article 5 (Permanent Establishment);


b) Subparagraphs e) and f) of paragraph 2, and paragraph 3 of Article 6 (Income from Immovable Property);


c) The phrase " or with other enterprises with which it deals " in paragraph 2 of Article 7 (Business Profits);


d) Paragraph 8 of Article 7 (Business Profits);


e) Subparagraphs c) and g) of paragraph 3 of Article 12 (Royalties); and


f) References to " income " (which includes profits and gains) in Article 13 (Alienation of Property).




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