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Comprehensive taxation agreement between Australia and Austria



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NO. 89

TREASURER

NO EMBARGO

STATEMENT BY THE TREASURER, THE HON. P.J.

COMPREHENSIVE TAXATION AGREEMENT BETWEEN AUSTRALIA AND AUSTRIA

COMMONWEALTH parliamentary library c. i. s.

KEATING, M.P.,

A comprehensive taxation agreement between Australia and Austria

will enter into force on 1 September 1988. Signature of the

agreement took place in Vienna on 8 July 1986, the details of

which were made public the following day. Legislation providing

for it to be given the force of law in Australia received the

Royal Assent on 4 November 1986.

Corresponding action has now been completed in Austria and the

formalities necessary to bring the agreement into force have

been concluded by an exchange of notes through the diplomatic

channel.

The agreement is a comprehensive one for the avoidance of double

taxation in relation to all income flowing between the two

countries. The allocation of taxing rights between the

countries accords with that provided for in Australia's other

modern comprehensive taxation agreements.

The agreement will have effect in Australia, for withholding tax

purposes, in respect of income derived on or after

1 January 1989 and, for other income tax purposes, in relation

to any year of income beginning on or after 1 July 1989. It

will first have effect in Austria, in relation to taxes withheld

at source, to amounts paid on or after 1 January 1989 and in

respect of other Austrian tax for any taxable year beginning on

or after 1 January 1989.

2 .

One effect of the agreement is that the rate of withholding tax

on dividends payable by Australian resident companies to

shareholders resident in Austria is reduced from 30 percent to

15 percent. Similarly, the tax on Interest and royalties

flowing from. Au-s t r a 1 i a to residents of Austria is limited under

the agreement to a maximum of 10 percent of the gross amount of

the interest or r oy a l t y . The limitation in respect of interest

and royalties will not affect Australia's Interest withholding

tax which is payable at the rate of 10 percent under our

domestic law. H ow e v e r , it will result in a reduction in

Australian tax on royalties flowing to Austria in cases where

the tax payable by assessment on the net royalty would have been

greater than that determined in accordance with the rate

specified in the agreement.

Under the terms of the a g r e e m e n t , Austria will similarly limit

its tax on d i v i d e n d s , interest and royalties flowing from

Austria to residents o f 'A u s t r a l i a .

Formal notification of the entry into force of the agreement on

1 September 1988 will be published in the Gazette as soon as

practicable after that date.

CANBERRA ACT

25 August 1988

Contact Officer : W. Ryan Phone : 062 - 751211(w)