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Edited version of your private ruling
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Ruling
Subject: Exemption of Australian interest withholding tax
Question
Is the foreign government entity entitled to an exemption from liability to interest withholding under Article 11(3) of the International treaty between the foreign country and Australia in respect of interest derived from debt instruments entered into by Australian borrowers?
Answer
Yes.
This ruling applies for the following periods:
3 years
The scheme commences on:
2012
Relevant facts and circumstances
The foreign government entity lends to Australians who import the foreign country goods. The entity uses the funds of the official reserve assets of the foreign government.
Relevant legislative provisions
Treaty between the foreign country and Australia
Reasons for decision
The treaty provides that interest derived from Australian loans is exempt from Australian withholding tax provided the investment is made from official reserve assets
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