The Australian Taxation Office has published draft Taxation Ruling TR 2005/5DC2 (PDF with tracked changes), which provides extensive guidance on the ascertainment of the right to tax financial institutions under the tax treaties with the U.S. and the UK in respect of interest income arising in Australia. Draft TR 2005/5DC2 includes proposed changes to TR 2005/5 to clarify the ATO's view on aspects of the definition of 'financial institution' as used in Australia's tax treaties with the U.S. and the UK. One important change concerns the application of the ruling beyond the U.S. or UK tax treaties. This includes that...