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Treaty shopping & Part IVA

Published on 27 Feb 98 by VICTORIAN DIVISION, THE TAX INSTITUTE

- can you afford to go treaty shopping?
- does Part IVA apply?
- some observations from Lamesa

Author profile

Hon Ian Vitaly Gzell AM QC QC FTI-Life
The Hon. Justice Ian Gzell FTIA (Life) was admitted to the Queensland Bar in 1965 and was appointed Queen’s Counsel in Queensland in 1977. He was appointed to the Equity Division of the Supreme Court of New South Wales in 2002 where, apart from his other duties, he is the Revenue List Judge. He was admitted as a Barrister in every state and territory in Australia and in New Zealand and Papua New Guinea, with admissions for multiple single causes in Singapore, Fiji and the Solomon Islands. At the Bar, Ian specialised in revenue law with particular emphasis on international taxation. He was President of The Taxation Institute from 1985-1986, President of the Commercial Law Association of Australia from 1994-1996 and has been Vice President, Western Pacific, of The International Academy of Estate and Trust Law since 2005 and Chairman of the Society of Trust and Estate Practitioners, Australia, Sydney Branch since 2007. He has had numerous articles published and is in constant demand as a speaker. - Current at 17 October 2017
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This was presented at Red Series: International Tax Masterclass .

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Individual sessions

Transferor Trusts

Author(s):  Richard SHADDICK

Materials from this session:

Permanent Establishments: Common & Topical Issues

Author(s):  Tim COX

Materials from this session:

Treaty Shopping & Part IVA

Author(s):  The Hon. Justice Ian GZELL

Materials from this session:

Application of business profits articles to CGT

Author(s):  Jason CHANG

Materials from this session:

Impact of 1997 legislative changes

Author(s):  Zorach DISKIN

Materials from this session:

Royalty WHT Issues and DTAS

Author(s):  Chris BIRCHALL

Materials from this session:

Cross border leasing

Author(s):  Charles ARMITAGE

Materials from this session:

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