Australian Tax Treaties
With reference to paragraph 4 of Article 27 :
It is understood that the reference to ' any provision of the laws of a Contracting State which is designed to prevent evasion or avoidance of taxes ' includes:
(a) in the case of Australia, Part IVA of the Income Tax Assessment Act 1936 or section 67 of the Fringe Benefits Tax Assessment Act 1986 ;
(b) in the case of Iceland, general anti-avoidance rules in the income tax law;
(c) measures designed to address thin capitalisation and dividend stripping;
(d) measures designed to address transfer pricing;
(e) controlled foreign company and transferor trust rules;
(f) measures designed to ensure that taxes can be effectively collected and recovered, including conservancy measures.
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