Australian Tax Treaties
With reference to paragraph 4 of Article 10 and paragraph 3 of Article 11 :
It is understood that the term " government investment fund " means an entity that satisfies all of the following conditions:
(a) the entity is:
(i) wholly owned by a Contracting State, or political subdivision or a local authority thereof; and
(ii) funded solely by public monies; and
(b) all returns on the entity ' s investments are public monies; and
(c) the entity is not :
(i) a partnership; or
(ii) an entity with a principal activity that consists of either or both of the following:
(A) producing or trading non-financial goods;
(B) providing services that are not financial services; or
(iii) an entity that:
(A) trades in financial assets and liabilities; or
(B) operates commercially in the financial markets; or
(C) has principal activities which include providing financial intermediary services, financial auxiliary services, or capital financial institution services.
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