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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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