Australia Tax Agency Issues Tax Ruling Addendum on Interpreting DTAs

The Australian Taxation Office March 18 issued a tax ruling addendum on interpreting Australia’s DTAs. The ruling includes: 1) general treaty concepts, rules, and principles; 2) the relationship between general domestic law and DTA terms; 3) the adoption of specific definitions from the International Tax Agreements Act; 4) the application of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) provisions; and 5) resolution procedures for dual residency and dual source income cases. The addendum applies retroactively from Oct. 13, 2010. [Australia, Australian Taxation Office, 03/18/20]

Reference:
View TR 2001/13A2. View ...