Non-resident withholding tax draft guidance

Clarifying the definition of a ‘financial institution’ for non-resident lenders.

The Australian Taxation Office has published a draft ruling consolidation TR 2005/5DC that proposes clarifications to Taxation Ruling TR 2005/5. Taxation Ruling TR 2005/5 was originally introduced to provide guidance for taxpayers around certain undefined terms within the financial institutions exemption from interest withholding tax under the United States (US) and United Kingdom (UK) Double Tax Conventions.Under Article 11(2) of Australia’s Double Tax Conventions with the US and UK, Austral...

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Authors: Natalie Raju, Matthew McRae,

Published Date: 05 December 2018