Australia Tax Agency Seeks Comments on Draft on Interest Paid to U.K., U.S. Financial Institutions

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Sept. 23, 2022, 5:00 AM

The Australian Taxation Office Sept. 21 opened a consultation on Draft Taxation Ruling No. TR 2005/5DC2, to clarify when U.S. and U.K. resident financial institutions aren’t subject to Australian tax on interest income arising in Australia. The ruling also applies to similar situations with residents of other countries with which Australia has a double-tax agreement (DTA) which meet particular requirements. The draft explains that Australia has no taxing rights when U.S. and U.K. residents: 1) meets the definition of “financial institution;” 2) are beneficially entitled to, or beneficially own, the interest; 3) are unrelated to, and deal independently from, the …



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