Treaty between Australia and United Kingdom – ATO interprets by reference to LOB provision in treaty between Australia and United States

The Australian Taxation Office (ATO) issued on 11 January 2008 Interpretative Decision ATO ID 2008/4 dealing with Art. 10.3 of the tax treaty between Australia nad the United Kingdom (UK Treaty), which provides for no source taxation of dividends in certain cases, including where the competent authority determines that, inter alia, the competent authority of the source state determines that the establishment, acquisition or maintenance of the beneficial owner of the dividends wa…