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Edited version of private advice

Authorisation Number: 1051632266977

Date of advice: 4 February 2020

Ruling

Subject: Withholding tax exemptions

The Commissioner was asked two questions about withholding tax on dividends paid by Australian resident companies from the investments held through XYZ (the FCP) and its sub-funds under subparagraph 4d) of Article 10 of the Convention between Australia and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes and Income, with Protocol [2014] ATS 33 (Swiss Convention)?

The Commissioner has ruled on each of the questions.