Australian Tax Treaties
Japanese Convention
CONVENTION BETWEEN AUSTRALIA AND JAPAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
SECTION (16)
(16)
With reference to paragraph 3 of Article 12 (Royalties) of the Convention:
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 3 of Article 12 (Royalties) of the Convention:
The term " royalties " shall not include payments for the use of spectrum licences. The provisions of Article 7 of the Convention shall apply to such payments.
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