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Edited version of your private ruling
Authorisation Number: 1012482645681
Ruling
Subject: International treaty and sovereign immunity
Question 1
Is the foreign government entity exempt from dividend and interest withholding taxes on Australian income under its country's treaty with Australia?
Answer
Yes
Question 2
Is the foreign government entity exempt from sundry other income on its Australian income under the common law principles of sovereign immunity
Answer
Yes
This ruling applies for the following periods:
1 July 2013 to 30 June 2018
The scheme commences on:
1 July 2008
Relevant facts and circumstances
The foreign government entity invests funds derived from fees raised for an accident compensation scheme.
Relevant legislative provisions
International Agreement
Reasons for decision
The foreign government entity satisfies the conditions of the international treaty for exemption from dividend and interest withholding taxes on its Australian investments and under the doctrine of sovereign immunity for its other income derived from MITs and VCLPs.