28 May 14 Taxable income of non-resident shipowner or charterer - TR 2014/2
On 28 May 2014 the ATO issued taxation ruling TR 2014/2 entitled “Income tax: the application of the ships and aircraft article of Australia’s tax treaties to taxable income derived under section 129 of the Income Tax Assessment Act 1936 by a non-resident shipowner or charterer”.
The ruling clarifies the circumstances in which the ships and aircraft article of Australia’s tax treaties allocates Australia a right to tax amounts falling within s 129 of the Income Tax Assessment Act 1936 (Cth). The ruling applies to treaty partner residents who carry on an enterprise for treaty purposes, and derive s 129 income from that enterprise in respect of the carriage of passengers, livestock, mails or goods shipped in Australia.
The ruling was previously issued in draft as TR 2013/D5.