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  

5.  
With reference to Article 10 (Dividends) of the Convention:

a) The term " Israeli REIT " means a " Real Estate Investment Fund " according to Article 64A2 of the Israeli Income Tax Ordinance.


b) The term " dividends " does not include " distributions by an Israeli REIT " .


c) With reference to paragraph 7, it is understood that a Contracting State is not required to provide a benefit under the Convention to a resident of the other Contracting State in relation to taxation by that other State of dividends that are not paid to, but are beneficially owned by, the resident.




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