Australian Tax Treaties
United Kingdom Convention
CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL GAINS
2003 UNITED KINGDOM NOTES
41/03 SECTION 2. 2.
With reference to Article 5 (Permanent establishment), the Contracting States agree that the term " permanent establishment " fully encompasses the concept of a " fixed base " used in other double tax treaties in the context of independent personal services.
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.
41/03 SECTION 2. 2.
With reference to Article 5 (Permanent establishment), the Contracting States agree that the term " permanent establishment " fully encompasses the concept of a " fixed base " used in other double tax treaties in the context of independent personal services.
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