29 April 2025

Synthesised texts of the MLI and Australia's tax treaties – update

The following synthesised texts were republished on 24 April 2025 with an updated presentation of the MLI Article 14(1) box or otherwise updated to ensure consistency of language, style and formatting, or both.
 
Denmark Synthesised text of the MLI and the Agreement between the Government of Australia and the Government of the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
India Synthesised text of the MLI and the Agreement between the Government of Australia and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as amended by the Amending Protocol
Indonesia Synthesised text of the MLI and the Agreement between the Government of Australia and the Government of the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
Ireland Synthesised text of the MLI and the Agreement between the Government of Australia and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
Korea Synthesised text of the MLI and the Convention between the Government of Australia and the Government of the Republic of Korea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, and Protocol
Netherlands Synthesised text of the MLI and the Agreement between Australia and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, as amended by the Second Protocol
New Zealand Synthesised text of the MLI and the Convention between Australia and New Zealand for the Avoidance of Double Taxation with respect to Taxes on Income and Fringe Benefits and the Prevention of Fiscal Evasion
Norway Synthesised text of the MLI and the Convention between Australia and the Kingdom of Norway for the Avoidance of Double Taxation with respect to Taxes on Income and the Prevention of Fiscal Evasion
Russia Synthesised text of the MLI and the Agreement between the Government of Australia and the Government of the Russian Federation for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
Singapore Synthesised text of the MLI and the Agreement between the Government of the Commonwealth of Australia and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as amended by the Amending Protocol and the Second Amending Protocol
Slovakia Synthesised text of the MLI and the Agreement between Australia and the Slovak Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
South Africa Synthesised text of the MLI and the Agreement between the Government of Australia and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, as amended by the Amending Protocol
Thailand Synthesised text of the MLI and the Agreement between Australia and the Kingdom of Thailand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
 

24 April 2025

 

Practice statements

PS LA 2007/6 – Update Guidelines for settlement of widely based tax disputes
 

23 April 2025

 

Rulings

CR 2025/28 Charter Hall Limited - capital reallocation
 

Legislative instrument

F2025L00517 Taxation Administration (Reporting Exemptions for Electronic Distribution Platform Operators) Determination 2025

Cases

 

17 April 2025

 

interpretation NOW!

Episode 119
 

16 April 2025

 

Rulings

CR 2025/26 Tower Limited - return of capital
CR 2025/27 Pacific Current Group Limited - off-market share buy-back
PR 2025/4 Commonwealth Bank of Australia - CommBank Yello
 

Practical compliance guidelines

PCG 2023/1 – Update Claiming a deduction for additional running expenses incurred while working from home - ATO compliance approach
 

10 April 2025

 

Practice statements

PS LA 2011/10 - Update Waiver of tax-related liabilities in proceeds of crime matters
 

9 April 2025

 

Rulings

PR 2025/3 RL360 Insurance Company Limited - Personal Investment Management Service
 

Notices

IT 2479W - Withdrawal Income tax: application of thin capitalisation rules
 

4 April 2025

 

Legislative instrument

F2025L00453 Student Assistance (Education Institutions and Courses) Amendment (Masters by Coursework) Determination 2025
F2025L00459 Income Tax Assessment (Build to Rent Developments) Amendment (Expanding Affordability Requirements) Determination 2025
 

3 April 2025

 

Practice statements

PS LA 2006/10 - Update The Commissioner's discretion to vary foreign resident withholding amounts
PS LA 2008/19 - Update Requests to amend income tax assessments
 

2 April 2025

 

Rulings

CR 2025/25 Auswide Bank Ltd - scheme of arrangement
 

28 March 2025

 

Decision impact statements

QUD 702 of 2024 Toowoomba Regional Council v Commissioner of Taxation [2025] FCA 161

interpretation NOW!

Episode 118
 

27 March 2025

 

Practice statements

PS LA 2013/4 – Update The ATO's role in the tax law design process
 

26 March 2025

 

Rulings

CR 2025/22 Suncorp Group Limited - special dividend, reduction of share capital and share consolidation
CR 2025/23 Latin Resources Limited - return of capital by in specie distribution of ESG Minerals Limited shares
CR 2025/24 Latin Resources Limited - scrip for scrip roll-over
 

Determinations

TD 2025/1 Fringe benefits tax: rates to be applied on a cents per kilometre basis for calculating the taxable value of a fringe benefit arising from the private use of a motor vehicle other than a car for the fringe benefits tax year commencing 1 April 2025
TD 2025/2 Fringe benefits tax: reasonable amounts under section 31G of the Fringe Benefits Tax Assessment Act 1986 for food and drink expenses incurred by employees receiving a living-away-from-home allowance fringe benefit for the fringe benefits tax year commencing 1 April 2025
 

Draft amendments

GSTR 2005/6DC Goods and services tax: supplies of things (other than goods or real property) made to non-residents but provided to another entity in Australia
GSTR 2007/2DC Goods and services tax: supplies where effective use or enjoyment of the supply take place outside Australia
 

20 March 2025

 

Practice statements

PS LA 2001/12 (Withdrawn) Lodgment of Ultimate Beneficiary (UB) Statements
PS LA 2005/17 - Update Pay as you go instalment income and foreign exchange realisation gains and losses
PS LA 2009/1 (Withdrawn) The Commissioner's discretion to issue a written notice specifying the amount of a tax offset for research and development allowable to an eligible company
 

Legislative instrument

F2025L00235 Taxation Administration (Defence Related International Obligations and Other Matters - Indirect Tax Refunds) Determination 2025
 

19 March 2025

 

Notices

CR 2024/58A1 – Addendum QV Equities Limited – scheme of arrangement
GSTR 2006/6A3 – Addendum Goods and services tax: improvements on the land for the purposes of Subdivision 38-N and Division 75
 

Decision impact statements

VID 903 of 2023 Commissioner of Taxation v Bendel [2025] FCAFC 15
 

7 March 2025

 

Taxpayer alerts

TA 2025/1 Managed investment trusts: restructures to access the managed investment trust withholding regime
 

6 March 2025

 

Practice statements

PS LA 2003/9 - Update Online Resource Centre for Law Administration
 

5 March 2025

 

Rulings

CR 2025/20 National sporting organisations - financial support provided to elite athletes
CR 2025/21 Premier Investments Limited - distribution of shares in Myer Holdings Limited
PR 2025/1 C2 Gateway Deferred Purchase Agreement
 

Determinations

TD 2025/D2 Income tax: disregarding certain payments under section 109R of the Income Tax Assessment Act 1936 in determining how much of a loan has been repaid in situations where notional loans are involved