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Contemporary treaty issues
Published on 01 Feb 23 by "THE TAX SPECIALIST" JOURNAL ARTICLE
This is a dynamic time in the evolution of Australia’s double tax treaty network following on from the previous government’s plans announced on 15 September 2021 to significantly expand the treaty network. Pleasingly, the Albanese Government has strongly supported and further expanded this important treaty initiative. This article focuses firstly on the overlay of the Multilateral Instrument, particularly the application of the limitation on benefits articles on access to concessional withholding taxes (dividends and royalties) under our covered tax agreements. Secondly, the article deals with special issues including dispute resolution arbitration, fiscally transparent entities/collective investment vehicles and the recent Maritime Boundary Treaty with Timor-Leste.
Author profile
Jock McCormack CTA
Jock McCormack, DLA Piper, is a leading Sydney-based international taxation lawyer with specific expertise in income tax and more than 30 years experience managing complex tax matters. Jock's major areas of expertise include debt and equity structuring, acquisitions/mergers/divestments, international tax including transfer pricing, capital gains tax and major projects taxation issues. Jock also advises various major corporations on ATO tax audits, tax strategy reviews, litigation and related issues including managing, negotiating and settling challenging and contentious tax issues and reviews. - Current at 24 November 2014
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