The Australian Taxation Office (ATO) has published guidance on the required supporting information for a competent authority determination under the Limitation on Benefits provisions in the tax treaties with the United Kingdom and the United States, as well as similar provisions in other treaties. Guidance is also provided on competent authority determinations in relation to dual residents under Australia's tax treaties that have been modified by Article 4(1) of the BEPS MLI. Article 4(1) serves to deny any relief or exemption from tax provided by a treaty if the competent authorities do not mutually agree on the residence of a...