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TD 2011/25 - Income tax: does the business profits article (Article 7) of Australia's tax treaties apply to Australian sourced business profits of a foreign Ltd partnership (LP) where the LP is treated as fiscally transparent in a country with which Australia has entered into a tax treaty (tax treaty country) and the partners in the LP are residents of that tax treaty country?   flag 

[2011] ATOTD TD2011/25
Australian Taxation Office
Australia - Commonwealth

Legislation Cited

Legislation Name Provision
Taxation Administration Act 1953 (Cth)

Cases and Articles Cited

Case Name Citation(s) Court Jurisdiction Date †  Full Text Citation Index
Convention Between Australia and the Kingdom of Norway for the Avoidance of Double Taxation With Respect To Taxes on Income and the Prevention of Fiscal Evasion (Canberra, 8 August 2006) [2006] ATNIA 37; [2007] ATS 32 Australia circa 2007 AustLII flag 4

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