Australian Tax Treaties
Ad Article 4
a) In respect of paragraph 1 of Article 4 , it is understood that the term " resident of a Contracting State " includes, in particular, a person that is:
(i) a pension scheme established in that State; and
(ii) an organization that is established and is operated exclusively for religious, charitable, scientific, cultural, sporting, or educational purposes (or for more than one of those purposes) and that is a resident of that State according to its laws, notwithstanding that all or part of its income, profits or gains may be exempt from tax under the domestic law of that State.
b) Where under this Convention any income, profits or gains are relieved from tax in Switzerland and, under the law in force in Australia, an individual in respect of that income or those profits or gains is exempt from tax by virtue of being a temporary resident of Australia within the meaning of the applicable tax laws of Australia, then the relief to be allowed under this Convention in Switzerland shall not apply to the extent that that income or those profits or gains are exempt from tax in Australia.
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