ARTICLE 6
1. Paragraph (6) of Article 7 of the Convention shall be deleted and replaced by the following:
“(6) Where profits include items which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.”.
2. A new paragraph (8) shall be added to Article 7 of the Convention as follows:
“(8) Where:
(a) a resident of Canada is beneficially entitled, whether directly or through one or more interposed trusts, to a share of the business profits of an enterprise carried on in Australia by the trustee of a trust other than a trust which is treated as a company for tax purposes; and
(b) in relation to that enterprise, that trustee would, in accordance with the principles of Article 5, have a permanent establishment in Australia,
the enterprise carried on by the trustee shall be deemed to be a business carried on in Australia by that resident through a permanent establishment situated in Australia and that share of business profits shall be attributable to that permanent establishment.”.
Australia / Canada · Australia–Canada 2002 amending Protocol
ARTICLE 6 ·
English · amending protocol
Unreviewed · applicability unverifiedNamed schedule only · parent volume incomplete
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Australia / Canada; International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3A; source scope International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3A; edition Protocol signed 23 January 2002; separate statutory source edition, not applied to base Convention; article 6; English; unreviewed source text, current applicability unverified; /editions/au-ca-2002-protocol-official-schedule-v1/en/articles/article-6/
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International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3A
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Complete Schedule3A2002amending Protocol, ending before Schedule4; parent2010volume incomplete.
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- International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3A
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Source language clause (not a claim of supplied translations): DONE at Canberra, this twenty‑third day of January 2002, in the English and French languages, the two versions being equally authentic.
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- Protocol signed 23 January 2002; separate statutory source edition, not applied to base Convention
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- 2002-01-23
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