Australian Tax Treaties
Swiss Convention
CONVENTION BETWEEN AUSTRALIA AND THE SWISS CONFEDERATION FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME, WITH PROTOCOL
SECTION 8
8
Ad Articles 10, 11 and 12
a) It is understood that for dividends and interest arising in Switzerland and derived by an Australian pension scheme, that pension scheme shall be regarded as the beneficial owner of such income where that income is treated as the income of that pension scheme for the purposes of Australian tax.
b) It is understood that for dividends, interest and royalties arising in Switzerland and derived by or through a discretionary trust, the trustee of that trust shall not be regarded as the beneficial owner of such income where the trustee subsequently distributes that income to a beneficiary that is not a resident of Australia, unless that income is subject to tax in Australia in the hands of the trustee and the Australian tax paid by the trustee is not subsequently refunded to that beneficiary.
Ad Articles 10, 11 and 12
a) It is understood that for dividends and interest arising in Switzerland and derived by an Australian pension scheme, that pension scheme shall be regarded as the beneficial owner of such income where that income is treated as the income of that pension scheme for the purposes of Australian tax.
b) It is understood that for dividends, interest and royalties arising in Switzerland and derived by or through a discretionary trust, the trustee of that trust shall not be regarded as the beneficial owner of such income where the trustee subsequently distributes that income to a beneficiary that is not a resident of Australia, unless that income is subject to tax in Australia in the hands of the trustee and the Australian tax paid by the trustee is not subsequently refunded to that beneficiary.
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