Australian Tax Treaties
Japanese Convention
CONVENTION BETWEEN AUSTRALIA AND JAPAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
SECTION (17)
(17)
With reference to subparagraph (e) of paragraph 3 of Article 12 (Royalties) of the Convention:
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
With reference to subparagraph (e) of paragraph 3 of Article 12 (Royalties) of the Convention:
It is understood that the term " forbearance in respect of the use or supply of any property or right " applies to cases where the holder of any property or right receives a payment or provides credits, as consideration, for not making such property or right available to another person.
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