The new Australia-UK tax treaty

The 2003 double taxation treaty largely reflects the 2001 Australia/US Protocol with some common elements with the new UK/US treaty. The main novelties are in the areas of dual listed companies, partnerships, employment and non-discrimination. In a number of respects, however, Australia is still a l...

Full description

Saved in:
Bibliographic Details
Published in:British Tax Review 2004-05 (3), p.194
Main Authors: Vann, Richard J, Oliver, J David B
Format: Article
Language:English
Subjects:
Double taxation
Permanent establishment
Tax treaties
Taxation
Online Access:Get full text
Tags: Add Tag
No Tags, Be the first to tag this record!
Description
Summary:The 2003 double taxation treaty largely reflects the 2001 Australia/US Protocol with some common elements with the new UK/US treaty. The main novelties are in the areas of dual listed companies, partnerships, employment and non-discrimination. In a number of respects, however, Australia is still a long way from the OECD Model, particularly in relation to permanent establishments, international transport, equipment leasing, and capital gains. Notwithstanding these concerns, the 2003 treaty is a significant advance on the 1967 treaty. Particularly from Australia's viewpoint it represents the first full treaty since the recent review of the tax treaty policy and represents a significant shift away from source taxation. The UK has, however, managed in negotiation to achieve a significant advantage on the 1967 convention even if the result is not a truly modern treaty.
ISSN:0007-1870