Double tax agreements

Deduction: interest expense to fund general reserve liquid assets

Dual resident of Australia and Malaysia: permanent home available

Japanese Special Income Tax for Reconstruction and Article 2 of the Japanese Double Tax Convention

Japanese Special Corporation Tax for Reconstruction and Article 2 of the Japanese Double Tax Convention

Canadian Convention - Article 15(2)(c): Deductibility of employees' remuneration in determining the taxable profits of the deemed Australian permanent establishment of a non-resident employer

Income tax: is the Macau Special Administrative Region (SAR) covered by the Australia-China Double Taxation Agreement on or after 20 December 1999?

Income tax: treaty shopping - can Part IVA of the Income Tax Assessment Act 1936 apply to arrangements designed to alter the intended effect of Australia's International Tax Agreements network?

Income tax: can the profit on the sale of shares in a company group acquired in a leveraged buyout be included in the assessable income of the vendor under subsection 6-5(3) of the Income Tax Assessment Act 1997?

Income tax: is an 'Australian source' in subsection 6-5(3) of the Income Tax Assessment Act 1997 dependent solely on where purchase and sale contracts are executed in respect of the sale of shares in an Australian corporate group acquired in a leveraged buyout by a private equity fund?

Income tax: does the business profits article (Article 7) of Australia's tax treaties apply to Australian sourced business profits of a foreign limited 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?

Income tax: is the Commonwealth Scientific and Industrial Research Organisation (CSIRO) an educational institution for the purposes of the articles in Australia's double tax agreements (DTAs) dealing with the remuneration of professors and teachers?

Income tax: does the definition of 'the Netherlands' in the Australia-Netherlands Double Tax Agreement ('the DTA') include Aruba and the Netherlands Antilles?

Income tax: does the definition of 'United Kingdom' in the Australia-United Kingdom Double Tax Agreement ('the DTA') include British possessions?

Income tax: does the definition of 'France' in the Protocol to the Australia-France Double Tax Agreement ('the DTA') include the French Territories?

Income tax: does the definition of 'United States' in the Australia-United States Double Tax Convention include United States possessions?

Income tax: how does the time threshold in the substantial equipment provision of the permanent establishment article of the Australia-Spain Double Taxation Agreement ('the DTA') operate?

Income tax: what is the source of income, profits or gains derived by taxpayers from petroleum activities within Area A of the Zone of Cooperation established under the Treaty between Australia and the Republic of Indonesia on the Zone of Cooperation in an Area between the Indonesian Province of East Timor and Northern Australia ('the Timor Gap Treaty')?

Income tax: withholding tax and related implications for a non-resident head lessor or hire-purchase provider of substantial equipment where the equipment is obtained by another non-resident entity that subleases, subprovides or leases it for use in Australia

Income tax: the taxation treatment of ship and aircraft leasing profits under the ships and aircraft articles of Australia's tax treaties

Income tax: the identification of 'employer' for the purposes of the short-term visit exception under the Income from Employment Article, or its equivalent, of Australia's tax treaties