Part II EXCHANGE OF NOTES
No LGB 03/170
The Department of Foreign Affairs and Trade presents its compliments to the British High Commission to Australia and has the honour to refer to the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Australia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains which has been signed today (the “Convention”).
The Department has the honour to make the following proposals on behalf of the Government of Australia:
- 1With reference generally to the application of the Convention (including these Notes),
- 2With reference to Article 5 (Permanent establishment),
- 3With reference to Article 7 (Business profits),
- 4With reference to Article 9 (Associated enterprises),
- 5With reference to Article 10 (Dividends),
- 6With reference to Article 11 (Interest),
- 7With reference to Article 12 (Royalties),
- 8With reference to Article 14 (Income from employment),
- 9With reference to Article 25 (Non-discrimination),
- 10With reference to Article 26 (Mutual agreement procedure) and Article 27 (Exchange of information),
- 11With reference to Article 26 (Mutual agreement procedure),
- 12Miscellaneous