ATO Publishes Revised Ruling on the Right to Tax Interest Income of Financial Institutions Under U.S. and UK Tax Treaties

On 17 May 2023, the Australian Taxation Office (ATO) published a revised version of Taxation Ruling TR 2005/5, which provides extensive guidance on the ascertainment of the right to tax financial institutions under the tax treaties (conventions) with the US and the UK in respect of interest income arising in Australia. One important change concerns the application of the ruling beyond the US or UK tax treaties. This includes that the ruling also covers interest income derived by financial in…