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On 22 October 2014, the ATO issued the following addendum to TD 2011/25:

  • TD 2011/25A1 - Income tax: does the business profits article (Article 7) of Australia's tax treaties apply to Australian sourced business profits of a foreign limited partnership (LP) where the LP is treated as fiscally transparent in a country with which Australia has entered into a tax treaty (tax treaty country) and the partners in the LP are residents of that tax treaty country?

The addendum inserts "; the profits are not dealt with under another Article of the Treaty (such as Article 13);" after the words "residence of the partners" in para 1.

The addendum applies on and from 1 October 2014.

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