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20 Dec 07 PE: Hire by non-resident of substantial equipment used in Australia - TD 2007/31

This final Taxation Determination was issued on 19 December 2007. It was previously released in draft form as TD 2007/D11: see 2007 TAXVINE No 22 (9) (8 June 2007). Its full title is "Income tax: is a non-resident enterprise that under a hire-purchase agreement hires out substantial equipment to another entity that uses the equipment in Australia deemed to have a permanent establishment in Australia under Article 4(3)(b) of the tax treaty between Australia and Singapore or equivalent provisions in other Australian tax treaties?" The answer given is No.

For a copy of TD 2007/31, go here

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