OrbitaxTax treaty between Australia and United States – Australia's Federal Court rejects tax treaty override
|Treaty Development|Australia-United States
The Federal Court of Australia on 19 April 2007 handed down its decision in GE Capital Finance Pty Ltd v Commissioner of Taxation [2007] FCA 558 rejecting the Commissioner's contentions that a tax treaty may be overridden by the Act which enacts that treaty.
The case involved a unit trust, resident in Australia by virtue of the trustee being resident in Au…
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