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27 Oct 11 Business profits article and foreign limited partnership - TD 2011/25

On 26 October 2011, the ATO issued Taxation Determination TD 2011/25, entitled "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?"

It was previously released in draft form as TD 2010/D8.

The answer to the question posed by the Determination is: "Yes, to the extent the business profits are treated as the profits of the partners (and not the LP) for the purposes of the taxation laws of the country of residence of the partners and the resident partners meet any other applicable tax treaty requirements. The Article will also apply to the extent that a partner in a LP is itself a LP and its partners (the ultimate partners) are residents of a tax treaty country."

 


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