Australian Tax Treaties
With reference to paragraph 5 of Article 13 (Alienation of Property) of the Convention:
It is understood that paragraph 5 does not prevent a Contracting State from taxing a person who was its resident and has become a resident of the other Contracting State in respect of income, profits or gains that the person is treated as having derived up to the time of the change of residency, in accordance with the domestic law of the first-mentioned state.
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