Australian Tax Treaties
With reference to paragraph 4 of Article 10 and paragraph 3 of Article 11 :
It is understood that the term " government investment fund " means an entity that satisfies all of the following conditions:
(a) the entity is:
(i) wholly owned by a Contracting State, or political subdivision or a local authority thereof; and
(ii) funded solely by public monies; and
(b) all returns on the entity ' s investments are public monies; and
(c) the entity is not :
(i) a partnership; or
(ii) an entity with a principal activity that consists of either or both of the following:
(A) producing or trading non-financial goods;
(B) providing services that are not financial services; or
(iii) an entity that:
(A) trades in financial assets and liabilities; or
(B) operates commercially in the financial markets; or
(C) has principal activities which include providing financial intermediary services, financial auxiliary services, or capital financial institution services.
This information is provided by CCH Australia Limited Link opens in new window. View the disclaimer and notice of copyright.