Australian Tax Treaties
Mexican Agreement
AGREEMENT BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE UNITED MEXICAN STATES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
SECTION (7)
(7)
With reference to paragraph 2 of Article 11,
(a) The term " recognized securities market " means:
(b) The provisions of this paragraph shall not apply to interest derived from back-to-back loans. In such case, the interest shall be taxable in accordance with the domestic law of the State in which it arises.
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.
With reference to paragraph 2 of Article 11,
(a) The term " recognized securities market " means:
(i) in the case of Mexico, stock exchanges duly authorized under the terms of the Stock Market Law ( Ley del Mercado de Valores ) of 2 January, 1975;
(ii) in the case of Australia, a stock exchange authorized under the laws of Australia; and
(iii) any other stock exchange agreed upon by the competent authorities of the Contracting States.
(b) The provisions of this paragraph shall not apply to interest derived from back-to-back loans. In such case, the interest shall be taxable in accordance with the domestic law of the State in which it arises.
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