Australian Tax Treaties
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.
This Convention shall continue in effect indefinitely, but either Contracting State may terminate the Convention by giving written notice of termination, through the diplomatic channel, to the other State at least 6 months before the end of any calendar year beginning after the expiration of 5 years from the date of its entry into force and, in that event, the Convention shall cease to be effective:
(a) in the case of Australia:
(i) in respect of withholding tax on income that is derived by a non resident, in relation to income derived on or after 1 January in the calendar year next following that in which the notice of termination is given;
(ii) in respect of other Australian tax, in relation to income, profits or gains of any year of income beginning on or after 1 July in the calendar year next following that in which the notice of termination is given;
(b) in the case of France:
(i) in respect of taxes on income withheld at source, for amounts taxable after the calendar year in which the notice of termination is given;
(ii) in respect of taxes on income which are not withheld at source, for income relating, as the case may be, to any calendar year or accounting period beginning after the calendar year in which the notice of termination is given;
(iii) in respect of the other taxes, for taxation the taxable event of which will occur after the calendar year in which the notice of termination is given.
In witness whereof the undersigned, duly authorised thereto, have signed this Convention.
Done in duplicate at Paris this twentieth day of June two thousand and six in the English and French languages, both texts being equally authentic.
| FOR THE GOVERNMENT OF
AUSTRALIA: |
FOR THE GOVERNMENT OF
THE FRENCH REPUBLIC: |
| Alexander Downer
Minister for Foreign Affairs |
Philippe Douste
-
Blazy
Minister for Foreign Affairs |
PROTOCOL
THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE FRENCH REPUBLIC
Have agreed at the signing of the Convention between the two Governments for the avoidance of double taxation with respect to taxes on income and the prevention of fiscal evasion upon the following provisions, which shall form an integral part of the said Convention (in this Protocol referred to as " the Convention " ):
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