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Edited version of private advice
Authorisation Number: 1052174102639
Date of advice: 7 November 2023
Ruling
Subject: Withholding tax - dividends - double tax convention
The Commissioner was asked about withholding tax on dividends paid by Australian resident companies from the investments held through a fund and its sub-funds under the relevant provisions of the Double Taxation Convention.
The Commissioner has ruled on the question.