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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   flag 

[2014] ATOTR TR2014/2
Australian Taxation Office
Australia - Commonwealth

Legislation Cited

Legislation Name Provision
Income Tax (International Agreements) Amendment Bill 1984 (Cth)
Income Tax Assessment Act 1936 (Cth) s129
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 Republic of Turkey for the Avoidance of Double Taxation with respect to Taxes on Income and the Prevention of Fiscal Evasion (Ankara, 28 April 2010) [2013] ATS 19 Australia circa 2013 AustLII flag 2
Income and Fringe Benefits and the Prevention of Fiscal Evasion [2010] ATS 10 Australia circa 2010 AustLII flag 6
Convention Between the Government of Australia and the Government of the French Republic for the Avoidance of Double Taxation with respect to Taxes on Income and the Prevention of Fiscal Evasion and Protocol (Paris, 20 June 2006) [2009] ATS 13 Australia circa 2009 AustLII flag 2
Convention Between Australia and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, Protocol, and Exchange of Notes (Tokyo, 31 January 2008) [2008] ATS 21 Australia circa 2008 AustLII flag 8
Income and the Prevention of Fiscal Evasion [2007] ATNIA 2; [2007] ATS 36 Australia circa 2007 AustLII flag 6
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
Agreement Between the Government of Australia and the Government of the United Mexican States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect To Taxes on Income (Mexico City, 9 September 2002) [2004] ATS 4 Australia circa 2004 AustLII flag 10
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 flag 21
Treaty Notes [2003] ATS 14 Australia circa 2003 AustLII flag 6
Treaty Notes [2003] ATS 23 Australia circa 2003 AustLII flag 5
Treaty Notes [2002] ATS 26 Australia circa 2002 AustLII flag 6
Treaty Notes [2001] ATS 4 Australia circa 2001 AustLII flag 5
Treaty Notes [1999] ATS 34 Australia circa 1999 AustLII flag 3
Agreement between the Government of Australia and the Government of the Argentine Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, and Protocol [1999] ATS 36 Australia circa 1999 AustLII flag 3
Treaty Notes [1999] ATS 35 Australia circa 1999 AustLII flag 2
Agreement between Australia and the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1995] ATS 30 Australia circa 1995 AustLII flag 2
Agreement between Australia and the Kingdom of Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, and Protocol [1992] ATS 41 Australia circa 1992 AustLII flag 5
Agreement between the Government of Australia and the Government of the Socialist Republic of Vietnam for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1992] ATS 44 Australia circa 1992 AustLII flag 7
Treaty Notes [1992] ATS 18 Australia circa 1992 AustLII flag 2
Treaty Notes [1992] ATS 40 Australia circa 1992 AustLII flag 2
Treaty Notes [1992] ATS 14 Australia circa 1992 AustLII flag 2
Agreement between the Government of Australia and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1991] ATS 49 Australia circa 1991 AustLII flag 10
Agreement between Australia and the Democratic Socialist Republic of Sri Lanka for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1991] ATS 42 Australia circa 1991 AustLII flag 2
Agreement between Australia and the Republic of Kiribati for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1991] ATS 34 Australia circa 1991 AustLII flag 4
Protocol amending the Agreement between the Government of the Commonwealth of Australia and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income of 11 February 1969 [1990] ATS 3 Australia circa 1990 AustLII flag 6
Agreement between Australia and Fiji for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1990] ATS 44 Australia circa 1990 AustLII flag 4
Treaty Notes [1990] ATS 45 Australia circa 1990 AustLII flag 6
Treaty Notes [1989] ATS 36 Australia circa 1989 AustLII flag 5
Agreement between Australia and the Independent Papua New Guinea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1989] ATS 37 Australia circa 1989 AustLII flag 7
Agreement between Australia and the Republic of Austria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1988] ATS 21 Australia circa 1988 AustLII flag 8
Agreement between Australia and Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1985] ATS 15 Australia circa 1985 AustLII flag 2
Income, and Protocol [1985] ATS 27 Australia circa 1985 AustLII flag 4
Treaty Notes [1984] ATS 2 Australia circa 1984 AustLII flag 3
Income and Capital Gains [1983] ATS 25 Australia circa 1983 AustLII flag 5
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 flag 37
Agreement between the Government of Australia and the Government of Malaysia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (Canberra, 20 August 1980) [1981] ATS 15 Australia circa 1981 AustLII flag 3
Convention between Australia and Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1981] ATS 14 Australia circa 1981 AustLII flag 11
Treaty Notes [1981] ATS 26 Australia circa 1981 AustLII flag 4
Agreement between Australia and Switzerland for the Avoidance of Double Taxation with respect to Taxes on Income [1981] ATS 5 Australia circa 1981 AustLII flag 14
Treaty Notes [1981] ATS 18 Australia circa 1981 AustLII flag 2
Treaty Notes [1980] ATS 16 Australia circa 1980 AustLII flag 4
Agreement between Australia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1979] ATS 21 Australia circa 1979 AustLII flag 2
Agreement between Australia and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, and Protocol [1976] ATS 24 Australia circa 1976 AustLII flag 7
Treaty Notes [1975] ATS 8 Australia circa 1975 AustLII flag 4
Treaty Notes [1969] ATS 14 Australia circa 1969 AustLII flag 13

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