AUSTRALIAN TAX TREATIES
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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