TAXATION (INTEREST ON OVERPAYMENTS AND EARLY PAYMENTS) REGULATIONS 1992 (REPEALED)
REGULATION 8
8
PRESCRIBED MANNER OF OPERATION OF BUSINESS PROFITS PROVISIONS
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JURIDICAL DOUBLE TAX RELIEF (ACT, PARAGRAPH 3A(2)(b))
For the purposes of paragraph 3A(2)(b) of the Act, the following manner of operation of Article 7 of the Vietnamese agreement is prescribed:
(a) in the case that the taxpayer is a resident of Australia - if the paragraph applies in a manner which increases the profits of the taxpayer which are attributable to a permanent establishment in the primary foreign country; or
(b) in the case that the taxpayer is not a resident of Australia - if the paragraph applies in a manner which decreases the profits of the taxpayer which are attributable to a permanent establishment in Australia.
For the purposes of paragraph 3A(2)(b) of the Act, the following manner of operation of Article 7 of the Vietnamese agreement is prescribed:
(a) in the case that the taxpayer is a resident of Australia - if the paragraph applies in a manner which increases the profits of the taxpayer which are attributable to a permanent establishment in the primary foreign country; or
(b) in the case that the taxpayer is not a resident of Australia - if the paragraph applies in a manner which decreases the profits of the taxpayer which are attributable to a permanent establishment in Australia.
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