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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

Legislation Cited

Legislation Name	Provision
Taxation Laws Amendment (Foreign Income) Bill 1990 (Cth)
Banking Act 1959 (Cth)	s5, s8, s9, s66
Income Tax Assessment Act 1936 (Cth)
Taxation Administration Act 1953 (Cth)

Cases and Articles Cited

Case Name	Citation(s)	Court	Jurisdiction	Date †	Full Text		Citation Index
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	[2003] ATS 22		Australia	circa 2003	AustLII		21
Commissioner of Taxation v Comcorp Australia Ltd	[1996] FCA 848; (1996) 70 FCR 356; (1996) 21 ACSR 590; (1996) 14 ACLC 1616	Federal Court of Australia	Australia - Commonwealth	24 Sep 1996	AustLII		51
Collis v FCT	(1996) 33 ATR 438		Australia	circa 1996	Legal Online / Westlaw		50
Commissioner for Superannuation v Scott	[1987] FCA 79; (1987) 13 FCR 404; 13 FLR 404; (1987) 71 ALR 408; (1987) 12 ALD 38; 6 AAR 143	Federal Court of Australia	Australia - Commonwealth	11 Mar 1987	AustLII		627
Convention between the Government of Australia and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income	[1983] ATS 16		Australia	circa 1983	AustLII		37

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