Treaties between Australia and Netherlands, and between Australia and United Kingdom – ATO confirms Australian Federal Court judgments that no tax on capital gains under pre-CGT treaties
The Australian Taxation Office (ATO) issued on 29 July 2009 a Decision Impact Statement on the judgments in Virgin Holdings SA v FCT [2008] FCA 1503 and Undershaft (No 1) Ltd v FCT [2009] FCA 41.
In these judgments, the Federal Court disagreed with the arguments advanced by the Commissioner that tax treaties entered into before the introduction of the Capital Gains Tax in Au…Continue Reading