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Convention between the Government of Australia and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains     21

Cases Referring to this Case

Case Name	Citation(s)	Court	Jurisdiction	Date †	Full Text		Citation Index
TD 2022/9 - Income tax: is section 951A of the US Internal Revenue Code a provision of a law of a foreign country that corresponds to sections 456 or 457 of the Income Tax Assessment Act 1936 for the purpose of subsection 832-130(5) of the Income Tax Assessment Act 1997 ?	[2022] ATOTD TD2022/9	Australian Taxation Office	Australia - Commonwealth	circa 2022	AustLII
TD 2022/9 - Income tax: is section 951A of the US Internal Revenue Code a provision of a law of a foreign country that corresponds to sections 456 or 457 of the Income Tax Assessment Act 1936 for the purpose of subsection 832-130(5) of the Income Tax Assessment Act 1997 ?	[2022] ATOTD 9	Australian Taxation Office	Australia - Commonwealth	circa 2022	AustLII
Addy v FCT	[2021] HCA 34; (2021) 273 CLR 613; (2021) 394 ALR 214; (2021) 95 ALJR 911	High Court of Australia	Australia - Commonwealth	3 Nov 2021	AustLII		7
Commissioner of Taxation v Addy	[2020] FCAFC 135; 280 FCR 46; 382 ALR 68	Federal Court of Australia	Australia - Commonwealth	6 Aug 2020	AustLII		20
Addy v Commissioner of Taxation	[2019] FCA 1768	Federal Court of Australia	Australia - Commonwealth	30 Oct 2019	AustLII		7
Bywater Investments Ltd v FCT	[2016] HCA 45; (2016) 260 CLR 169; [2016] ATC 20-589; 91 ALJR 59	High Court of Australia	Australia - Commonwealth	16 Nov 2016	AustLII		23
Bywater Investments Ltd v Commissioner of Taxation	[2015] FCAFC 176; (2015) 236 FCR 520; (2015) 329 ALR 385	Federal Court of Australia	Australia - Commonwealth	11 Dec 2015	AustLII		6
Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4)	[2015] FCA 1092; (2015) 102 ATR 13	Federal Court of Australia	Australia - Commonwealth	23 Oct 2015	AustLII		22
Hua Wang Bank Berhad v Commissioner of Taxation	[2014] FCA 1392; (2014) 100 ATR 244	Federal Court of Australia	Australia - Commonwealth	19 Dec 2014	AustLII		22
TD 2014/13 - Income tax: the application of Article 10 2(a) of the United Kingdom Convention	[2014] ATOTD 13	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
TR 2014/2 - Income tax: the application of the ships and aircraft article of Australia's tax treaties to taxable income derived under section 129 of the Income Tax Assessment Act 1936 by a non-resident shipowner or charterer	[2014] ATOTR 2	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
TR 2014/3 - Income tax: satisfying the 'carrying on a business at or through a permanent establishment' requirement in section 23AH of the Income Tax Assessment Act 1936 where a Co is taken to have a permanent establishment (PE) in relation to substantial equipment	[2014] ATOTR TR2014/3	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
TR 2014/2 - Income tax: the application of the ships and aircraft article of Australia's tax treaties to taxable income derived under section 129 of the Income Tax Assessment Act 1936 by a non-resident shipowner or charterer	[2014] ATOTR TR2014/2	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
TR 2014/3 - Income tax: satisfying the 'carrying on a business at or through a permanent establishment' requirement in section 23AH of the Income Tax Assessment Act 1936 where a Co is taken to have a permanent establishment (PE) in relation to substantial equipment	[2014] ATOTR 3	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
TD 2014/13 - Income tax: the application of Article 10 2(a) of the United Kingdom Convention	[2014] ATOTD TD2014/13	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
Hua Wang Bank Berhad v Commissioner of Taxation (No 2)	[2012] FCA 938; (2012) 298 ALR 178	Federal Court of Australia	Australia - Commonwealth	31 Aug 2012	AustLII		6
TR 2005/5 - Income tax: ascertaining the right to tax United States (US) and United Kingdom (UK) resident financial institutions under the US and the UK Taxation Conventions in respect of interest income arising in Australia	[2005] ATOTR TR2005/5	Australian Taxation Office	Australia - Commonwealth	circa 2005	AustLII
TR 2005/5 - Income tax: ascertaining the right to tax United States (US) and United Kingdom (UK) resident financial institutions under the US and the UK Taxation Conventions in respect of interest income arising in Australia	[2005] ATOTR 5	Australian Taxation Office	Australia - Commonwealth	circa 2005	AustLII
TR 2001/13 - Income tax: Interpreting Australia's Double Tax Agreements	[2001] ATOTR TR2001/13	Australian Taxation Office	Australia - Commonwealth	circa 2001	AustLII
TR 2001/13 - Income tax: Interpreting Australia's Double Tax Agreements	[2001] ATOTR 13	Australian Taxation Office	Australia - Commonwealth	circa 2001	AustLII

Law Journal Articles Referring to this Case

Journal Article Title	Citation(s)	Author	Jurisdiction	Date †	Full Text		Citation Index
"An Old Tax is a Simple Tax: A Back to the Future Suggestion for the Simplification of Australian Corporate-Shareholder Taxation"	[2006] JlATaxTA 4	Taylor, C John	Australia	circa 2006	AustLII

Legislation Cited