| Disclaimer This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law. You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4. |
Edited version of your private ruling
Authorisation Number: 1012464130516
Ruling
Subject: Do the activities of the taxpayer amount to permanent establishment in Australia
Question 1
Do the activities of the taxpayer amount to a permanent establishment in Australia under Article 5 of the Convention between the Government of Australia and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains [2003] ATS 22 (UK Convention)?
Answer
Yes.
This ruling applies for the following periods:
Year ending 31 December 2013.
The scheme commences on:
1 January 2013.
Reasons for decision
The private binding ruling concerned whether or not the activities of the taxpayer amount to a permanent establishment in Australia under Article 5 of the UK Convention.
The Commissioner of Taxation ruled that the activities of the taxpayer amount to a permanent establishment in Australia under Article 5 of the UK Convention.