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 4. 4.
With reference to Article 9 (Associated enterprises), the Contracting States note that the expression " dealing wholly independently with one another " is included in paragraph 1 of the Article to conform to Australia ' s consistent treaty practice and to address Australia ' s concerns that the appropriate benchmark for determining the conditions operating between the associated enterprises should have regard to whether those dealings between the enterprises occurred on a truly independent basis.
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 4. 4.
With reference to Article 9 (Associated enterprises), the Contracting States note that the expression " dealing wholly independently with one another " is included in paragraph 1 of the Article to conform to Australia ' s consistent treaty practice and to address Australia ' s concerns that the appropriate benchmark for determining the conditions operating between the associated enterprises should have regard to whether those dealings between the enterprises occurred on a truly independent basis.
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