Double tax agreements paper

Published on 13 Aug 09 by QUEENSLAND DIVISION, THE TAX INSTITUTE

Double tax agreements are an important mechanism for assigning taxing rights between two taxing jurisdictions or eliminating issues relating to the double taxing of income. However, due to a lack of understanding of their operation, many advisors may be incorrectly or under utilising these important agreements. This paper explores the use of double tax agreements including "how to" actually read them and "when to" use the agreements for clients where more than one jurisdiction is involved in the taxation of their income. In particular, the more relevant provisions such as the tie breaker tests and the 183 day exemption for employment income as well as those dealing with the limitation of or exemption from tax on certain types of income is covered.

Author profile

Natalie Frame

Natalie is a Manager in Brisbane’s Human Capital Division of Ernst & Young. She has over six years experience specialising in all taxation related matters arising for employers and employees as a result of international assignments. Natalie’s experience includes assisting with their international assignment policies and advising companies on all employment tax matters. Natalie also has extensive experience in advising both employers and participants on the Australian tax implications of employee share and option plans. - Current at 02 July 2009

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