Australian Tax Treaties
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.
This information is provided by CCH Australia Limited Link opens in new window. View the disclaimer and notice of copyright.