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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 private advice

Authorisation Number: 1052070464985

Date of advice: 14 December 2022

Ruling

Subject: CGT - double tax agreements

The Commissioner issued a ruling that relates to the following provisions:

Income Tax Assessment Act 1997 Subdivision 104-A

Income Tax Assessment Act 1997 Subdivision 768-G

Income Tax Assessment Act 1997 section 770-10

Other References

Convention Between Australia and The Republic of Chile for the Avoidance of Double Taxation with Respect to Taxes on Income and Fringe Benefits and the Prevention of Fiscal Evasion.