07 Jun 077 Income tax: effect of McDermott v FCT for Singaporean resident hirer - TD 2007/D11This draft Taxation Determination was released on 6 June 2007 for public comment by 6 July 2007. Its full title is "Income tax: will the hire of substantial equipment in Australia under a hire-purchase agreement create a deemed permanent establishment for a Singaporean resident hirer under Article 4(3)(b) of the tax treaty between Australia and Singapore as a result of the decision in McDermott Industries (Aust) Pty Ltd v. Federal Commissioner of Taxation  FCAFC 67?" The answer given is Yes. The Commissioner's interpretation is not limited to Article 4(3)(b) of the Singapore Agreement but also applies in respect of the other tax treaties specified in the Taxation Determination.
For a copy of TD 2007/D11, go here