Australian Tax Treaties

Israeli Convention  

CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE STATE OF ISRAEL FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE  

SECTION 1.  

1.    
In general:

Nothing in this Convention shall prevent the application of any provision of the laws of a Contracting State which is designed to prevent the avoidance or evasion of taxes, including:

a) measures designed to address thin capitalisation and dividend stripping;

b) measures designed to address transfer pricing;

c) controlled foreign company and transferor trust rules;

d) measures designed to ensure that taxes can be effectively collected and recovered, including conservancy measures;

e) foreign occupational company rules;

f) in the case of Australia, Part IVA of the Income Tax Assessment Act 1936 or section 67 of the Fringe Benefits Tax Assessment Act 1986 ;

g) in the case of Israel, Article 86 of the Income Tax Ordinance 5721-1961.