The Double Taxation Convention is an agreement between the New Zealand Government and the Australian Government to avoid double taxation of income and ancillary benefits. How can I request a competent authority, in accordance with Article 10(3)(c) of the Double Taxation Convention, that the payment of a given dividend is subject to a withholding tax rate of zero? 2.376 As discussed in the OECD Model Commentary, the arbitration mechanism is not an alternative to the cartel procedure. If the competent authorities have reached an agreement which leaves no questions unanswered, that case shall not be eligible for arbitration, even if the taxable person does not agree with the solution obtained. However, if a matter remains outstanding and a charge contrary to the Convention is maintained, the competent authorities cannot examine (alone or jointly) whether the case is resolved and deny the person access to the arbitration mechanism. The new double taxation agreement between New Zealand and Australia has entered into force and reduces withholding tax rates on certain dividend, interest and licence payments between New Zealand and Australia, Finance Minister Peter Dunne announced today. 1.8 Applicable regulatory requirements must be imposed by laws, legal instruments, a mandatory code of a regulatory authority or other similar regulatory requirements. Therefore, the agreement reached for the creation of the DLC will not be a relevant regulatory requirement for the purpose of fulfilling the definition. 5.99 No substantial additional costs were found for taxable persons that could result from the Jersey Agreement. The agreement should simplify the tax obligations of companies falling within their scope.
“The new DBA builds on the already close economic relationship between our two countries and reflects the significant growth and changes in trade and investment between our two countries since the signing of the last agreement in 1995,” said Mr. Dunne. 5.97 The administrative impact of amendments to the ATO by new bilateral tax treaties (including tax treaties) is considered to be low. General questions may arise and some formal indications of interpretation, such as. Β binding private decisions may be necessary with regard to the application of the Jersey Agreement. ATO employees, taxpayers and tax specialists must be mobilised on the entry into force of the Jersey Agreement. As a result, a number of ATO information products need to be updated. This is normal in the context of a new tax treaty or bilateral agreement. 5.26 Both countries have specific policy objectives to achieve by updating the tax treaty, and the final outcome is the compromises necessary to reach a mutually acceptable agreement. Among the main changes to a new contract are: 2.82 Competent authorities shall take into account the place of management of the person, the place where he or she is registered or otherwise constituted, as well as all other relevant factors, as set out in paragraph 24 of the 2008 OECD Commentary on the OECD Model (OECD Model Commentary) on Article 4. In the absence of an agreement between the competent authorities, such a person shall not be entitled to an exemption or exemption provided for in the agreement. 2.180 It was expected that the competent authorities would reach an agreement that other stock exchanges constitute a recognized stock exchange within the meaning of the agreement.
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