Australian Tax Treaties
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
With reference to subparagraph (e) of paragraph 3 of Article 12 (Royalties) of the Convention:
It is understood that the term " forbearance in respect of the use or supply of any property or right " applies to cases where the holder of any property or right receives a payment or provides credits, as consideration, for not making such property or right available to another person.
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