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04 Jun 14 Application of Article 10.2(a) of the United Kingdom Convention - TD 2014/13

On 4 June 2014 the ATO issued taxation determination TD 2014/13 entitled “Income tax: the application of Article 10.2(a) of the United Kingdom Convention”.

The determination says that UK Co “holds directly” at least 10% of the voting power in Aus Co for the purposes of Article 10.2(a) of the United Kingdom double tax Convention where:

(a) a nominee shareholder owns shares carrying at least 10% of the voting power in Aus Co for the benefit of UK Co, and

(b) the nominee undertakes to UK Co to exercise all rights of voting and other privileges attaching to the shares in such manner as UK Co shall direct or approve.

The determination was previously issued in draft as TD 2014/D9.

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