Australian Tax Treaties
French Convention
CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE FRENCH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF FISCAL EVASION
ARTICLE 21
Source of Income
1.
Income, profits or gains derived by a resident of a Contracting State which, under Articles 6 to 8 , 10 to 16 and 18 may be taxed in the other Contracting State, shall be deemed to be income from sources in that other State.
2.
Profits included in the profits of an enterprise of a Contracting State under paragraph 1 of Article 9 shall for purposes of the taxation of that enterprise be deemed to be income of that enterprise derived from sources in that Contracting State.
3.
Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8 , 10 to 16 and 18 , may be taxed in the other Contracting State shall for the purposes of Article 23 and of the law of the first-mentioned Contracting State relating to its tax be deemed to arise from sources in 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.
Income, profits or gains derived by a resident of a Contracting State which, under Articles 6 to 8 , 10 to 16 and 18 may be taxed in the other Contracting State, shall be deemed to be income from sources in that other State.
2.
Profits included in the profits of an enterprise of a Contracting State under paragraph 1 of Article 9 shall for purposes of the taxation of that enterprise be deemed to be income of that enterprise derived from sources in that Contracting State.
3.
Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8 , 10 to 16 and 18 , may be taxed in the other Contracting State shall for the purposes of Article 23 and of the law of the first-mentioned Contracting State relating to its tax be deemed to arise from sources in the other Contracting State.
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