author_orbitax
Orbitax

Share This Article

ATO Issues Determination on Application of Australia-UK Tax Treaty Benefits when a Nominee Shareholder Holds Shares of an Australian Company

16 June 2014

|

Treaty Development

|

Australia-United Kingdom

On 4 June 2014, the Australia Taxation Office issued a taxation determination stating the conditions where the reduced dividend withholding tax benefits of the Australia-U.K. tax treaty will apply when a nominee shareholder holds shares of an Australian company for the benefit of a U.K. company. The conditions include: The nominee shareholder owns shares carrying at least 10 per cent of the voting power in the Australian company for the benefit of the U.K. company; and The U.K. company must direct or approve all rights of voting and other privileges attached to the shares as exercised by the nominee shareholder...