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 9. 9.
With reference to Article 25 (Non-discrimination), the Contracting States agree that:
(a) in relation to paragraph 4 and subparagraph 6(c) of the Article, the reference to capital being owned or controlled " directly or indirectly " includes cases where the capital is held through a chain of companies or other entities; and
(b) nothing in the Article shall be construed as obliging a Contracting State to allow tax rebates and credits in relation to dividends received by a person who is a resident of the other Contracting State.
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 9. 9.
With reference to Article 25 (Non-discrimination), the Contracting States agree that:
(a) in relation to paragraph 4 and subparagraph 6(c) of the Article, the reference to capital being owned or controlled " directly or indirectly " includes cases where the capital is held through a chain of companies or other entities; and
(b) nothing in the Article shall be construed as obliging a Contracting State to allow tax rebates and credits in relation to dividends received by a person who is a resident of the other Contracting State.
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