Australian Tax Treaties

Italian Airline Profits Agreement  

AGREEMENT BETWEEN THE GOVERNMENT OF THE COMMONWEALTH OF AUSTRALIA AND THE GOVERNMENT OF ITALY FOR THE AVOIDANCE OF DOUBLE TAXATION OF INCOME DERIVED FROM INTERNATIONAL AIR TRANSPORT  

ARTICLE 2  

(1)    
In this Agreement, unless the context otherwise requires -

(a) the term " Australia " includes any Territory of or under the authority of the Commonwealth of Australia and any Territory governed by it under a Trusteeship Agreement;

(b) the term " Italy " means the Italian Republic;

(c) the terms " Contracting State " and " other Contracting State " mean Australia or Italy, as the context requires;

(d) the term " Australian enterprise " means an enterprise that has its place of effective management in Australia;

(e) the term " Italian enterprise " means an enterprise that has its place of effective management in Italy;

(f) the term " enterprise of a Contracting State " means an Australian enterprise or an Italian enterprise, as the context requires;

(g) the term " tax " means Australian tax or Italian tax, as the context requires;

(h) the term " operation of aircraft in international traffic " means the operation of aircraft for the carriage of persons, livestock, goods or mail between -

(i) Australia and Italy;

(ii) Australia and any other country;

(iii) Italy and any other country;

(iv) countries other than Australia or Italy or places in any such country,

and in respect of an enterprise engaged in such operations includes the sale of tickets for, and the provision of services connected with, such carriage, either for the enterprise itself or for any other enterprise engaged in such operations.

(2)    
In the application of the provisions of this Agreement in one of the Contracting States, any term used but not defined herein shall, unless the context otherwise requires, have the meaning which it has under the laws in force in that Contracting State relating to the taxes to which this Agreement applies.