Australian Tax Treaties
In respect of paragraph 3 of Article 7, no account shall be taken in the determination of the profits of a permanent establishment, of amounts paid or charged, (otherwise than towards reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on money lent by or to the head office of the enterprise or any of its other offices.
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