Australian Tax Treaties
Korean Convention
CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE REPUBLIC OF KOREA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
CHAPTER III
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TAXATION OF INCOME
ARTICLE 8
Ships and Aircraft
(1)
Profits of a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2)
The provisions of paragraph (1) shall also apply to profits derived from participation in a pool, a joint business or an international operating agency.
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.
Profits of a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2)
The provisions of paragraph (1) shall also apply to profits derived from participation in a pool, a joint business or an international operating agency.
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