CGT and non-residents: pre-CGT treaty question finally resolved.
28 Apr 09 |
CCH TAX WEEK
Issue: Issue 14 2009
This article discusses the decision in Undershaft (No 1) Ltd v FC of T 2009 ATC 20-091, which held that two pre-CGT treaties denied Australia the right to tax capital gains made by two non-resident companies.
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Justin ia an Associate Professor, Law School, James Cook University, Cairns, Australia; Adjunct research fellow in Business Law and Taxation, Faculty of Business and Economics, Monash University, Australia.
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01 April 2016