Possibly reflecting the widely differing economic interests and tax law structures of countries, there are very few multilateral tax treaties.

A common theme in relation to Australian offshore investment is that a DTA would reduce investor risks by putting in place an agreed framework for taxation of cross-border activities which would prevent double taxation. However, it should be noted that a DTA is not guaranteed to always prevent double taxation. For example, the definition given to certain terms by the internal law of the 2 countries may result in cases where the treaty allocates the same taxing rights over the same income to both countries. This is a problem with all tax treaties based on the OECD Model.On the other hand, because a DTA is largely based on standard international tax models (which have a body of supporting commentaries) it can be said there is a common international understanding of the meaning of many of its provisions. In addition, a DTA would contain procedures to enable the 2 governments to mutually agree on matters of interpretation and application to prevent double taxation.

Instead of imposing a DWT on dividend payments to shareholders, South Africa imposes a secondary tax on companies on declaration of dividends. The secondary tax is imposed in addition to the corporate tax and is currently imposed at the rate of 12.5% of net dividends (i.e. dividends declared less dividends received).

Source: Department of Foreign Affairs and Trade.

Possibly reflecting the widely differing economic interests and tax law structures of countries, there are very few multilateral tax treaties.

The requirement for bilateral agreement on reduction of source country taxation is understandable because both countries wish to be assured of reciprocal treatment of their residents.

Source: Department of Foreign Affairs and Trade

Comprehensive details of the quantum of these investments are currently unavailable.

Possibly reflecting the widely differing economic interests and tax law structures of countries, there are very few multilateral tax treaties.

A common theme in relation to all Australian activity in Argentina is that the DTA will reduce investor risks by putting in place an agreed framework for taxation of cross-border activities which will prevent double taxation. However, it should be noted that a DTA is not guaranteed to always prevent double taxation. For example, the definition given to certain terms by the internal law of the 2 countries may result in cases where the treaty allocates the same taxing rights over the same income to both countries. This is a problem with all tax treaties based on the OECD Model.On the other hand because the proposed DTA is largely based on standard international tax models (which have a body of supporting commentaries) it can be said there is a common international understanding of the meaning of many of its provisions. In addition it contains procedures to enable the 2 governments to mutually agree on matters of interpretation and application to prevent double taxation.