OrbitaxAllocation of income under article 8 of Australian treaties
|Treaty Development|Australia
On 28 August 2013, the Australian Taxation Office released for comment Draft Taxation Ruling TR 2013/D5 (the Draft Ruling) that deals with the circumstances in which the ships and aircraft article of Australia's double tax treaties (equivalent to article 8 of the OECD Model) allocates Australia a right to tax and how that income is taxed under the domestic provisions.
The Draft Ruling say…
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