OrbitaxATO denies interest withholding tax exemption to a US pension fund
|Treaty Development|Australia-United States
The Australian Taxation Office (ATO) issued Interpretative Decision ID 2006/141 on the application of interest withholding tax exemption to a United States limited liability company (US LLC) under the Australia-US tax treaty (the tax treaty).
Under Art. 11(3)(a) of the tax treaty, an exemption from interest withholding tax is available, inter alia, for …
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