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 7.  

7.    
With reference to subparagraph a) of paragraph 2 of Article 11 (Interest) of the Convention:

It is understood that the term " Financial Institution " does not include an insurance company, " a lending fund " , a corporate treasury or a member of a group that performs the financing services of the group.

For the purposes of this paragraph, it is understood that the term " lending fund " means an entity that is formed by investors and has the primary purpose of making investments through interest bearing loans.




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